International
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December 02, 2024
'Harry Potter' Actor Must Pay £1.8M Tax Bill, Tribunal Says
Actor Rupert Grint, who portrayed Ron Weasley in the Harry Potter film series, faces a £1.8 million ($2.3 million) tax bill after the U.K.'s First-tier Tribunal ruled that tax avoidance was a primary purpose of an entity created to manage his career.
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December 02, 2024
IRS Floats Pooling, Annual Accounting In Offshore Profit Regs
U.S. multinational companies will be required to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits under proposed rules floated by the U.S. Treasury Department and Internal Revenue Service.
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December 02, 2024
A&O Shearman Tax Pro Jumps To Hogan Lovells In DC
Hogan Lovells said Monday that it has brought on a former Allen Overy Shearman Sterling tax partner who specializes in spinoffs, cross-border deals and other corporate transactions.
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December 02, 2024
IRS Finalizes Partnership Liability Regs After 11 Years
The Internal Revenue Service unveiled final regulations governing the allocation of partnership liabilities 11 years after releasing the proposed rules, saying no subsequent legislative and regulatory changes had taken place to compel the agency to otherwise renew the rulemaking process.
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December 02, 2024
Australia Passes Public Country-By-Country Reporting
Multinational businesses with large operations in Australia are required to publicly disclose information about their operations in tax havens as designated by the government under a country-by-country reporting law that lawmakers adopted following a two-year saga over concerns about the data's confidentiality.
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December 02, 2024
Skat Settles With Ex-Barclays Director In £1.4B Fraud Case
The Danish tax authority has settled its claim against a former Barclays Capital director and four companies that it sued alongside dozens of others over an alleged scheme to defraud it of £1.4 billion ($1.8 billion) in tax revenue.
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December 02, 2024
Sports Direct's Ashley Says HMRC Bungled His Data Request
Sports Direct International PLC founder Michael Ashley argued in a London court Monday that the U.K.'s tax agency improperly handled his data request related to its probe into his 2012 sale of real estate assets, calling its alleged failings "significant, wide-spread and persistent."
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December 02, 2024
Australia Seeks Input On Tax Treaty With Portugal
Australia's Treasury is looking for feedback on plans to implement a treaty with Portugal that would address concerns of double taxation and alleviate cross-border costs by establishing lower withholding rates, the agency said Monday.
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December 02, 2024
5 Convicted In €14M COVID Test VAT Fraud Scheme
A German court convicted five people for their roles in a value-added tax fraud scheme involving the sale of COVID-19 tests that caused about €14 million ($14.7 million) in VAT losses, the European Public Prosecutor's Office said.
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November 29, 2024
Audit Watchdog Urges EU To Curb Harmful Tax Practices
The European Union is still not doing enough to stop harmful corporate tax practices that are costing governments more than €100 billion ($105 billion) a year in revenue, the bloc's independent audit watchdog has warned.
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November 28, 2024
Police Detain 32 People In Raids On €297M VAT Fraud Network
Police have detained more than 30 people in raids on a €297 million ($313 million) value-added tax fraud network that spanned 16 EU countries, the European Public Prosecutor's Office said Thursday.
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November 28, 2024
EU Closes Tax Investigations Into Amazon, Fiat, Starbucks
The European Commission said Thursday that it is closing tax investigations into three multinational companies — Amazon, Fiat and Starbucks — following a series of high-profile court decisions.
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November 28, 2024
Ex-HMRC Compliance Officer Helped Husband Launder £3M
A former compliance officer with HM Revenue and Customs has been handed a suspended sentence for her role in a £3 million ($3.8 million) money laundering operation carried out by her husband, the Crown Prosecution Service has said.
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November 28, 2024
AXA Loses Time Limits Appeal In HMRC Foreign Tax Claim
Insurer AXA has lost its fight over time limits for bringing claims for restitution against the British tax authority over taxes collected in violation of European Union law, as a London appeals court ruled that the limits could not be extended.
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November 27, 2024
UN Approves Start Of Formal Talks On Global Tax Convention
The United Nations General Assembly voted Wednesday in favor of beginning formal negotiations on a global tax convention next year with the goal of finishing in 2027, a proposal that was led by the body's African bloc and won support from 125 countries.
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November 27, 2024
US Says Prof's 8th Amendment Argument Fails In FBAR Case
An 86-year-old former professor cannot claim that his $545,000 penalty for failing to report foreign bank accounts violates the Eighth Amendment, the U.S. told a federal court, saying the penalty is neither excessive nor a fine, and that he never raised the argument before.
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November 27, 2024
BlueCrest Disputes 'Disguised Salary' Claim In HMRC Case
British-American hedge fund BlueCrest Capital Management LLP pushed back Wednesday against arguments from the U.K. tax authority that its portfolio managers are employees receiving a disguised salary.
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November 27, 2024
US Seeks FBAR Penalties Over $1.7M In Foreign Accounts
A Texas woman should face penalties for willfully failing to disclose foreign bank accounts from 2011 through 2013, which held balances exceeding $1.7 million, the U.S. government told a federal court Wednesday.
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November 27, 2024
UK Gambling Levy Would Generate £100M, Gov't Says
A new levy on U.K. gambling operations would generate £100 million ($127 million), which would be earmarked for funding various ways to combat problem gambling, a government agency said Wednesday.
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November 27, 2024
Info On €12T In Assets Swapped Last Year, OECD Says
Tax jurisdictions using the Organization for Economic Cooperation and Development's automatic exchange of information frameworks swapped information on 134 million financial accounts last year, representing nearly €12 trillion ($12.7 trillion) in assets, according to an OECD forum report.
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November 26, 2024
Ukrainian Man Admits To $25M Staffing, Tax Scheme
A Ukrainian man who was recently extradited to the U.S. to face charges that he helped illegally employ immigrants in Florida hotels pled guilty to tax crimes that prosecutors say caused $25 million in tax losses, according to Florida federal court filings.
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November 26, 2024
Jones Walker Welcomes New Commercial, Tax Atty
Jones Walker LLP has added a corporate partner who practices tax law and negotiates, structures and drafts complex merger and acquisition transactions, financings and related contracts and agreements, the firm said.
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November 26, 2024
Australia Will Enact Pillar 2 Minimum Corporate Tax
Australia will institute the Organization for Economic Cooperation and Development's global corporate minimum tax under legislation enacted Tuesday by Parliament.
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November 26, 2024
Many OECD Gov'ts Need More Tax Transparency, Report Says
Peer reviews found nearly half of OECD countries need to improve their legal frameworks for the automatic exchange of financial account information, a decade-old tax transparency system crafted by the organization, while many developing countries received passing grades, according to a report released Tuesday.
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November 26, 2024
OECD Suggests Indonesia Broaden Its Tax Base
Indonesia should broaden its tax base to account for long-term spending pressures like an aging population, the Organization for Economic Cooperation and Development said Tuesday, while also recommending the country pick up the pace on implementing a carbon tax.
Expert Analysis
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Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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7 Common Myths About Lateral Partner Moves
As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.