International

  • June 14, 2024

    G7 Chiefs Agree On Using Frozen Russian Profits For Ukraine

    Leaders from the Group of Seven countries reached a provisional agreement to use windfall profits from frozen and immobilized Russian state assets to back a $50 billion loan to Ukraine, they announced Friday, although details have to be ironed out before the end ot the year, said Italy's prime minister, Giorgia Meloni.

  • June 14, 2024

    Swiss Council OKs Tax Agreements With Angola, Germany

    Switzerland's executive body, the Federal Council, approved a double taxation agreement with Angola and an amendment to an existing agreement with Germany, it announced Friday.

  • June 14, 2024

    Taxation With Representation: Kirkland, Arnold & Porter

    In this week's Taxation with Representation, Noble Corp. PLC buys Diamond Offshore Drilling Inc., Cognizant buys Belcan, AlphaSense raises funding to buy Tegus, and Matador Resources Co. acquires a subsidiary of the EnCap Investments portfolio company Ameredev II Parent.

  • June 14, 2024

    ABA Tax Section Calls For Revision To Stock Buyback Regs

    The U.S. Department of the Treasury and the IRS should narrow a rule in proposed regulations on the stock buyback tax regarding U.S. subsidiaries funding repurchases of their foreign parents' stock, the American Bar Association's Tax Section said in a letter released Friday.

  • June 14, 2024

    Full DC Circ. Won't Hear Foreign Disclosure Penalty Dispute

    The D.C. Circuit declined to reconsider its ruling overturning a major U.S. Tax Court decision that had crimped the administrative collection arm of the Internal Revenue Service, letting stand a panel's restoration of the agency's power to more freely penalize undisclosed foreign corporations.

  • June 14, 2024

    UK Broker Denied Supreme Court Hearing Over Cum Ex Raids

    Judges at a London court refused on Friday to allow a brokerage to challenge at the U.K. Supreme Court findings that a raid on its London office during an investigation into tax fraud in 2022 was legal, finding that the "outcome of any appeal would be no different."

  • June 14, 2024

    EU Transfer Pricing Law To Involve Basic Rights, Prof Says

    A proposed European Union law on transfer pricing would, if adopted, mean the EU's charter of fundamental rights became relevant to transfer pricing disputes, a tax professor said Friday.

  • June 13, 2024

    Canada Should Look Beyond Capital Gains Tax Hike, IMF Says

    Though Canada's proposed capital gains tax increase would be another positive development for a country that has largely fared well in its pandemic rebound, the country should consider more avenues to raise revenue, the International Monetary Fund said.

  • June 13, 2024

    Denmark Considering $302M Entrepreneur Tax Break Package

    Denmark's finance ministry announced a package of more than 2.1 billion kroner ($302 million) in tax breaks and other measures for entrepreneurs that it says will help drive innovation and overall grow the country's attractiveness for startups.

  • June 13, 2024

    Labour Manifesto Targets Wealthy To Fill Funding Gaps

    Labour set out plans in its election manifesto on Thursday to raise a total of more than £8.5 billion ($10.8 billion) in tax reforms that target wealthy taxpayers, although some analysts questioned whether the measures will add up.

  • June 13, 2024

    EU Eyeing Exchange Rules Linked To Min. Tax, Official Says

    The European Union is looking to introduce rules regarding the exchange of information pertaining to the global minimum corporate tax, a top official in the EU's executive branch said Thursday.

  • June 13, 2024

    Swiss Finance Minister Defends Tax Competition

    Switzerland's finance minister defended tax competition, saying citizens' right to move to lower-tax jurisdictions helps keep public authorities from taxing and spending to excess.

  • June 13, 2024

    EU Scales Back Talks On Proposed Law To Combat Shell Cos.

    European Union countries have broadly agreed to work on a scaled-back legislative proposal to combat shell companies that would give each country more freedom to decide what anti-abuse action to take, an EU official said.

  • June 12, 2024

    Senate Budget Chair Seeks End To Carried Interest Tax Break

    Lawmakers should end the favorable tax treatment of income from carried interest compared with ordinary earned income, Senate Budget Committee Chairman Sheldon Whitehouse said Wednesday.

  • June 12, 2024

    Digital Taxes May Take Hold Regardless Of Treaty Signing

    An internationally agreed-upon freeze on digital levies may continue to thaw even if countries meet their impending deadline to sign a related treaty for new corporate tax rules, in part because the accord faces a hazy path to formal ratification.

  • June 12, 2024

    Feds Strike Deal Ending $7M FBAR Penalty Cases

    The U.S. government agreed to settle a pair of foreign bank account reporting cases in which it had sought a total of $7 million from a former insurance broker and his wife's estate, according to a court order filed Wednesday in California federal court.

  • June 12, 2024

    Groups Push Back On Stock Buyback Tax Test's Scope

    The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.

  • June 12, 2024

    Aussie Senate's Final PwC Report Focuses On Integrity Recs

    Australia's Senate released its final report Wednesday regarding PwC's marketing of confidential draft tax laws to clients, pushing for both consulting firms and the government to assure that the firms, particularly the Big Four, act with integrity.

  • June 12, 2024

    Treasury Issued Over $1B In Clean Vehicle Tax Credits

    The clean vehicle tax credit of up to $7,500 has saved buyers more than $1 billion in total upfront costs since January, the U.S. Treasury Department announced Wednesday, saying the figures represent a major milestone in lowering transportation costs since the incentive was updated in 2022.

  • June 12, 2024

    Italy Investigating €13M VAT Fraud Involving Chinese Fabric

    An Italian judge issued a freezing order against four people and a company as investigations continue into a scheme involving the illegal importation of Chinese fabric that caused over €13 million ($14.1 million) in value-added tax losses, the European Public Prosecutor's Office said Wednesday.

  • June 12, 2024

    New Dutch Gov't Agrees On Top Finance Official

    The incoming right-wing Dutch government has agreed to appoint a conservative politician as finance minister and to maintain a separate position for the state secretary for taxation in order to comply with a recent Netherlands Supreme Court tax ruling on compensation to investors, Dutch media reported.

  • June 11, 2024

    US Issues Sanctions For $50M Guyana Gold Tax Evasion

    Two Guyanese businessmen and a Guyanese official were sanctioned by the U.S. Treasury Department on Tuesday after a probe into a corruption scheme that helped the businessmen evade $50 million in gold export taxes that should have been paid to Guyana's government, Treasury said.

  • June 11, 2024

    Latvia Renominates EU Trade Commissioner To Retain Role

    The Latvian government has renominated former Prime Minister Valdis Dombrovskis to retain his European Commission position as the commissioner for trade, the government announced Tuesday.

  • June 11, 2024

    Extension OK'd For Carbon Program Tax Exemption In Norway

    An extension of a program that makes certain carbon emissions tax-exempt for some Norwegian businesses was approved by an official watchdog group Tuesday.

  • June 11, 2024

    Compliance Costs Outweigh Min. Tax Gains, Biz Reps Say

    Multinational businesses are concerned that the burden of complying with the 15% global minimum tax outweighs any potential revenue gains associated with the burgeoning system, tax attorneys and a trade association representative said during a panel Tuesday.

Expert Analysis

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

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