International

  • October 28, 2024

    US Expatriations Tick Up In 3rd Quarter, IRS Says

    The number of people who expatriated from the U.S. rose during the third quarter of the year compared with the previous quarter, the Internal Revenue Service said Monday.

  • October 25, 2024

    German Drug Co. Due £21.5M VAT Refund, UK Tribunal Finds

    A German pharmaceutical provider is entitled to a refund of almost £21.5 million ($27.9 million) for the value-added tax it paid on the rebated portion of products supplied to the U.K.'s National Health Service, the British First-tier Tribunal ruled.

  • October 25, 2024

    Lebanon, Angola, Others Added To Financial Crime Watch List

    An intergovernmental task force on financial crimes added Lebanon, Angola, Algeria and the Ivory Coast to a watch list of countries with weak protections against money laundering and financing for armed groups, the group said Friday.

  • October 25, 2024

    Argentina Formally Shutters, Replaces Tax Agency

    Argentina's president formally dissolved the country's tax agency, the Federal Public Revenue Administration, and established a new agency, following through on an announcement two days earlier to end what he characterized as an oversize entity.

  • October 25, 2024

    Authorities Bust €113M VAT Fraud Ring Between Italy, China

    A sting carried out Friday by the European Public Prosecutor's Office busted a crime ring involving the import of clothing and accessories from China to Italy that hid the goods' origins in order to evade €113 million ($122 million) in value-added taxes, the EPPO said.

  • October 25, 2024

    Taxation With Representation: Davis Polk, Skadden, Kirkland

    In this week's Taxation With Representation, Atlantic Union Bankshares Corp. absorbs Sandy Spring Bancorp, Sophos and Secureworks merge, Wendel Group takes a stake in Monroe Capital LLC, and Acuity Brands Inc. buys QSC LLC.

  • October 25, 2024

    MVP: Wachtell's Tijana J. Dvornic

    Wachtell Lipton Rosen & Katz's Tijana J. Dvornic led the firm's tax team in representing Lumen Technologies in the largest liability management transaction outside of bankruptcy protections, including addressing over $15 billion of existing debt, earning her a spot as one of the 2024 Law360 Tax MVPs.

  • October 25, 2024

    Germany's Expected Tax Take For 5 Years Drops €58B

    Germany expects to raise €58.2 billion ($63 billion) less in revenue through 2028 than what was forecast in May, according to the country's finance minister, who said that the government allowing employers to pay tax-free bonuses caused uncertainties regarding income tax collections.

  • October 24, 2024

    IRS To End Automatic Foreign Gift Reporting Penalty

    Internal Revenue Service Commissioner Danny Werfel told the UCLA Tax Controversy Conference audience on Thursday that the agency will no longer automatically assess penalties for the late reporting of large foreign gifts, with the announcement eliciting applause from the audience of several hundred tax attorneys and tax professionals.

  • October 24, 2024

    IRS Forming Transfer Pricing Team To Aid Real-Time Audits

    The Internal Revenue Service is establishing a dedicated team to tackle transfer pricing issues that arise in real-time audits of companies participating in its compliance assurance process program, which should allow those issues to be handled more efficiently, an agency official said Thursday.

  • October 24, 2024

    Nigeria Frees Binance Exec Detained Over Money Laundering

    Nigeria's government released a top executive at cryptocurrency exchange Binance whom the government had been holding liable for money laundering charges against the company, the U.S. government and the exchange's CEO said Thursday.

  • October 24, 2024

    Wyden's Pharma Probe Could Build Case For Int'l Tax Reforms

    Senate Finance Committee Chairman Ron Wyden's investigation into the tax planning of major U.S. pharmaceutical companies could help fuel an effort to revamp U.S. international tax laws next year when Congress addresses expiring provisions of the Tax Cuts and Jobs Act.

  • October 24, 2024

    Politics Blocking Amount B Consensus, OECD Tells G20

    Continued delays of the Organization for Economic Cooperation and Development's transfer pricing plan for certain baseline marketing and distribution activities known as Amount B of Pillar One are due to "primarily political" issues as opposed to technical problems, the organization told the Group of 20 on Thursday.

  • October 24, 2024

    Dutch Gov't Seeks Feedback On Crypto Reporting Rules

    The Netherlands is looking for input on a proposal that would implement European Union rules requiring crypto-asset service providers to collect, check and share their users' data with the country's tax authority, the Dutch Ministry of Finance said Thursday.

  • October 24, 2024

    Aussie Board Seeks Input On Tax Pro Code Update Guidance

    The Australian Tax Practitioners Board is looking for feedback on guidance related to six amendments to the country's tax professional code of conduct that were made in response to the PwC document leak scandal, the board said Thursday.

  • October 24, 2024

    119K Residents Didn't Report Foreign Accounts, HMRC Says

    Around 119,000 U.K. residents failed to declare their foreign accounts in fiscal year 2018-19 with HM Revenue & Customs, the British tax authority said Thursday.

  • October 24, 2024

    Sweden Moves To Suspend Tax Treaty With Russia

    Sweden is looking to suspend its double-tax treaty with Russia in response to Russia's cessation of parts of their treaty last year, Sweden's Ministry of Finance said Thursday.

  • October 24, 2024

    MVP: Sidley's Rachel D. Kleinberg

    Rachel D. Kleinberg, a co-leader of the global tax practice at Sidley Austin LLP, headed up a tax team to represent investors in a consortium that led to the $6.05 billion sale of the NFL's Washington Commanders, earning her a spot as one of the 2024 Law360 Tax MVPs.

  • October 24, 2024

    Charles Russell Brings On Tax Specialist From Sheridans

    Charles Russell Speechlys LLP hired a partner from Sheridans as part of expanding its London tax practice to support its strategy focused on private capital, the firm said.

  • October 24, 2024

    Mining Eligible In Final Regs For Energy Manufacturing Credit

    The U.S. Treasury Department's final rules released Thursday on a valuable tax credit for manufacturing key components and materials used in clean energy technologies allow producers to take into account the costs to mine and extract critical minerals.

  • October 23, 2024

    IRS To Split Pass-Through, Energy Credit Work Into 2 Units

    The IRS is planning to split up its Pass-Throughs and Special Industries office into two separate divisions, including one that will focus in part on energy credits enacted under the 2022 landmark climate law, an agency official said Wednesday.

  • October 23, 2024

    COST Urges Justices To Hear IBM, Disney Appeals Of NY Tax

    New York's method of taxing IBM and The Walt Disney Co.'s royalties received from foreign affiliates resulted in an unconstitutional discrimination against interstate commerce that warrants U.S. Supreme Court scrutiny, the Council on State Taxation told the justices Wednesday.

  • October 23, 2024

    Microsemi's Fines Mostly Adhered To Rules, Tax Court Says

    The Internal Revenue Service obtained the proper written approval of penalties on most of the tax code violations it brought against semiconductor manufacturer Microsemi but left room for doubt on two penalties, the U.S. Tax Court said.

  • October 23, 2024

    ECJ Won't Call Off Clawback Of Portugal's Tax Breaks

    The European Court of Justice declined to overturn a European Commission decision that Portugal must claw back tax breaks provided in a free trade zone to companies with no local economic activity, as those breaks violated the bloc's state aid rules, according to a judgment issued Wednesday.

  • October 23, 2024

    Australian Greens Support Digital Tax On Tech Cos.

    The Australian Greens party recommended that the country's government pursue a digital services tax similar to those in France and Canada as a way to make companies such as Meta pay their "fair share."

Expert Analysis

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

  • Trauma-Informed Legal Approaches For Pro Bono Attorneys

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    As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.

  • How Attys Can Avoid Pitfalls When Withdrawing From A Case

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    The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.

  • Using A Children's Book Approach In Firm Marketing Content

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    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

  • New Crypto Reporting Will Require Rigorous Recordkeeping

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    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

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