International

  • December 13, 2024

    IRS Mulls Turning Off Foreign Currency Rules For CFCs

    The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.

  • December 13, 2024

    Halliburton Consistent On Claims For $35M Refund, Court Told

    Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.

  • December 13, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.

  • December 13, 2024

    Canada 2-Month Sales Tax Holiday Begins Saturday

    A two-month goods-and-services tax holiday in Canada on certain goods such as gifts and restaurant meals will begin Saturday after having passed the Senate and receiving royal ascension.

  • December 13, 2024

    Contractor Loses Bail For Texting Alleged Tax Cheat Allies

    A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.

  • December 13, 2024

    Loper Bright May Influence Tax Less, IRS Chief Counsel Says

    The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.

  • December 12, 2024

    IRS Wants Choice Retained In Dual Loss Rules, Official Says

    The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.

  • December 12, 2024

    IRS Seeks Feedback On Limits In Previous Taxed Profit Rules

    The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.

  • December 12, 2024

    CJEU Upholds €1.8M Tax On Volvo Group In Belgium

    Belgium can impose a "fairness tax" totaling €1.8 million ($1.9 million) on nonresident companies without a permanent office in the country, the Court of Justice of the European Union said Thursday.  

  • December 12, 2024

    2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties

    The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.

  • December 12, 2024

    Swiss To End Credit Offsetting India's Tax Treaty Snub

    The Swiss government will no longer offer a credit to taxpayers designed to offset India's rejection of Swiss claims to benefits offered in other Indian tax treaties because India's top court decided to uphold its government's position, according to a notice.

  • December 12, 2024

    German Fund Managers Charged In €45M Cum-Ex Scheme

    Two fund managers have been charged in Germany for "particularly serious" tax evasion over their alleged role in a €45 million ($47 million) cum-ex dividend tax fraud, prosecutors confirmed Thursday.

  • December 12, 2024

    IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

    Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.

  • December 12, 2024

    Treasury Seeks To Pause Anti-Laundering Law Injunction

    The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.

  • December 12, 2024

    Less Than Half Of Latin America Sees Taxes As Contributions

    Only 47% of surveyed Latin American taxpayers consider their taxes as a contribution to the overall good of society as opposed to a cost they are forced to pay, the Organization for Economic Cooperation and Development said Thursday, saying the figure was below the global average.

  • December 12, 2024

    Gibraltar Considering Global Minimum Tax Bill

    Gibraltar's Parliament is considering the implementation of two parts of the Organization for Economic Cooperation and Development's 15% global corporate minimum income tax on large multinational entities making over €750 million ($786 million) annually.

  • December 12, 2024

    Mexico To Join Int'l Pricing Program In 2025, Official Says

    Mexico plans in 2025 to join the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues, an official from that country's tax authority said Thursday.

  • December 12, 2024

    Trader Sentenced To 12 Years For Cum-Ex Fraud In Denmark

    A Danish court sentenced a British hedge fund trader to 12 years in prison on Thursday after finding him guilty of defrauding the country's tax authority by masterminding a nine billion kroner ($1.3 billion) cum-ex fraud scheme.

  • December 11, 2024

    More Facts Needed In RJ Reynolds Tax Row, Mich. Court Says

    More facts are needed on whether part of a $4.9 billion sale of trademarks by R.J. Reynolds to a Japanese company should be taxable in Michigan, a state court said Wednesday, declining to rule immediately.

  • December 11, 2024

    Exxon Tax Ruling Doesn't Help Liberty Global, 10th Circ. Told

    Liberty Global cannot use a recent ruling that allowed Exxon Mobil a tax deduction for interest payments to claim a deduction for dividends that arose from its intragroup shuffling of a Belgian affiliate, the U.S. government told the Tenth Circuit on Wednesday.

  • December 11, 2024

    Irish Ruling Cuts Shareholder's Capital Gains Tax By €2.2M

    A shareholder who gave all his shares in a company to several entities will save €2.2 million ($2.3 million), as Ireland's Tax Appeals Commission said Wednesday that the disposal happened in multiple transactions, qualifying for a discounted capital gains tax rate.

  • December 11, 2024

    Estonia Passes 2% Tax To Fund Russia-Ukraine War Spending

    Estonia's Parliament passed a temporary 2% tax Wednesday, earmarked to cover increased defense spending for the Russia-Ukraine war, choosing to go a different route to raise funds than neighboring Lithuania and Latvia.

  • December 11, 2024

    Adidas Says European Offices Raided In EU Tax Investigation

    Authorities are searching Adidas AG's offices in Germany and Austria for evidence of tax evasion following a five-year investigation by customs authorities in the European Union, the company told Law360 on Wednesday.

  • December 11, 2024

    Netherlands Gov't Reports $5.3B Drop In Tax Avoidance

    The Dutch government said Wednesday that it has seen tax avoidance drop by €5 billion ($5.3 billion) since the imposition of two European Union directives targeting low-tax corporate structures and practices.

  • December 10, 2024

    FinCEN Says CTA Still Constitutional In Post-Injunction Alert

    The Financial Crimes Enforcement Network has alerted companies that they do not currently need to file so-called beneficial ownership information with the agency after a federal judge's nationwide preliminary injunction blocking the Corporate Transparency Act, though the bureau maintained that the law calling for such information is constitutional.

Expert Analysis

  • How Methods Are Evolving In Textualist Interpretations

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    Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.

  • Why Attorneys Should Consider Community Leadership Roles

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    Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.

  • Firms Must Offer A Trifecta Of Services In Post-Chevron World

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    After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.

  • 5 Tips To Succeed In A Master Of Laws Program And Beyond

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    As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.

  • How Law Firms Can Avoid 'Collaboration Drag'

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    Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.

  • Litigation Funding Disclosure Key To Open, Impartial Process

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    Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.

  • What NFL Draft Picks Have In Common With Lateral Law Hires

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    Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.

  • Replacing The Stigma Of Menopause With Law Firm Support

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    A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.

  • Planning Law Firm Content Calendars: What, When, Where

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    During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

  • It's Time For A BigLaw Associates' Union

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    As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.

  • How Justices Upended The Administrative Procedure Act

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    In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.

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