International

  • October 07, 2024

    Justices Won't Hear Man's FBAR Constitutionality Challenge

    The U.S. Supreme Court let stand Monday a Seventh Circuit decision dismissing a man's challenge to the constitutionality of the Bank Secrecy Act's requirement to report his foreign bank accounts, effectively ending the man's claim that the filings were an invasion of privacy.

  • October 07, 2024

    Jury Finds Professor Hid Foreign Bank Accounts

    An 86-year-old former college professor faces more than $500,000 plus interest in penalties after a jury found that he had deliberately failed to report his foreign bank accounts in Switzerland and Turkey, according to documents filed in a California federal court.

  • October 07, 2024

    Man Who Faced Espionage Case Gets Probation Over Taxes

    A Chinese engineer initially accused of illegally exporting documents on military aircraft to China was given probation and fined for failing to report about $1.4 million in business income by a Texas federal court after the government dropped its export charges.

  • October 07, 2024

    Singapore Seeks Comments On Min. Tax Safe Harbor Rules

    Singapore is looking for feedback on proposed safe harbor and transition rules that would complement its coming implementation of the OECD's Pillar Two global minimum tax on large multinational corporations, its revenue authority said.

  • October 07, 2024

    Norway's Gov't Looking To Close Exit Tax Loophole

    Norway's government said Monday that it is looking to close a loophole by adjusting its exit tax rules, though the tightening on when the tax must be paid would be paired with a 500% increase of the threshold for when the tax becomes applicable.

  • October 07, 2024

    Corp. Tactics May Call For Rethinking Tax Breaks, Paper Says

    Countries may want to look at scaling back corporate tax breaks to address tax planning opportunities taken advantage of by businesses over the past 20 years while those tax breaks have proliferated, according to a working paper published Monday by the Organization for Economic Cooperation and Development.

  • October 07, 2024

    India Seeking Feedback On Income Tax Regime

    India's government said Monday it is undergoing what it called a comprehensive review of its income tax regime in hopes of reducing litigation and increasing taxpayer certainty.

  • October 07, 2024

    TCJA Extension, Biz Tax Cut To Reward Top 5%, Report Says

    Former President Donald Trump's planned extension of the 2017 tax cuts and lowering of corporate rates contribute most among his platform to lowering taxes for the wealthiest 5% and hiking them for everyone else, the left-leaning Institute on Taxation and Economic Policy said Monday in a report.

  • October 05, 2024

    Biz Owners Saved £1.3B On Inheritance Tax, Report Says

    Business owners have saved their families an estimated £1.3 billion ($1.7 billion) last year by claiming business property relief on inheritance tax, according to law firm TWM Solicitors.

  • October 04, 2024

    DC Circ. Won't Reconsider Whistleblower's $690M Claim

    The D.C. Circuit on Friday rejected a whistleblower's request that it rehear a ruling upholding the denial of up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program.

  • October 04, 2024

    Promise Of OECD's Payments Tax Treaty Called Into Question

    The OECD-designed tool to provide developing countries with better means to apply a minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group is inadequate to address those countries' revenue needs, tax policy organizations said.

  • October 04, 2024

    Australia Wants Feedback On Tax Promoter Penalty Regime

    The Australian government asked Friday for feedback on the country's current tax promoter penalty regime as part of its efforts to strengthen its regulatory frameworks in the wake of the PwC document leak scandal.

  • October 04, 2024

    Europe Votes To Raise Tariffs On Electric Vehicles From China

    European Union member states voted Friday to impose higher tariffs on imports of battery electric vehicles from China for the next five years, adding to the already staggering tariffs imposed by the United States and Canada.

  • October 04, 2024

    Brazil Establishes 15% Global Min. Tax On Large Cos.

    Brazil's government has adopted the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational corporations making €750 million ($823 million) annually.

  • October 04, 2024

    Former NJ Doctor Owes $4.8M In FBAR Penalties, Court Told

    A former physician in New Jersey faces a tax bill of almost $5 million for failing to report 19 bank accounts he opened at Indian banks, the government told a federal court.

  • October 04, 2024

    ECJ Says Interest Deduction Limits Align With EU Law

    Governments across the European Union can legislate to block businesses from getting corporate tax deductions on interest paid as part of noncommercial loans, the European Court of Justice ruled Friday.

  • October 04, 2024

    Taxation With Representation: Gibson Dunn, Weil, Simpson

    In this week's Taxation with Representation, DirectTV buys EchoStar's video business for $10 billion, Marsh McLennan inks a $7.75 billion deal for McGriff Insurance, and PepsiCo closes a $1.2 billion deal to purchase Siete Foods.

  • October 04, 2024

    McDermott Taps Big 4 Partner As Senior Tax Pro In London

    McDermott Will & Emery LLP announced it has recruited a former U.K. partner from KPMG to join its firm as a tax partner, bringing an expert in private equity to its London office.

  • October 03, 2024

    12 Lawyers Who Are The Future Of The Supreme Court Bar

    One attorney hasn't lost a single U.S. Supreme Court case she's argued, or even a single justice's vote. One attorney is perhaps "the preeminent SCOTUS advocate." And one may soon become U.S. solicitor general, despite acknowledging there are "judges out there who don't like me." All three are among a dozen lawyers in the vanguard of the Supreme Court bar's next generation, poised to follow in the footsteps of the bar's current icons.

  • October 03, 2024

    US Partnership Excluded From Tax Treaty, Irish Court Says

    A Delaware corporation with three Irish subsidiaries must pay Irish taxes on distributions to its U.S. partners because a U.S.-Ireland tax treaty designed to prevent double taxation does not apply, the Irish High Court ruled.

  • October 03, 2024

    3M Tells 8th Circ. Chevron's End Dooms IRS In $24M Dispute

    Multinational conglomerate 3M said Thursday that the U.S. Supreme Court's striking down of Chevron deference dictates that the Eighth Circuit overturn a U.S. Tax Court decision that supported the IRS' reallocation of $24 million from the company's Brazilian affiliate.

  • October 03, 2024

    K&L Gates Boosts Houston Shop With Ernst & Young Tax Ace

    K&L Gates LLP strengthened its Houston office this week with the hire of a tax partner with nearly three decades of expertise in advising multinational corporations on U.S. taxation on cross-border acquisitions and other transactions.

  • October 03, 2024

    Aerospace Co. Says Conn. Town Wrongly Taxed $8M In Assets

    A unit of a U.K.-based aerospace manufacturer is claiming that a Connecticut town overvalued its taxable personal property by nearly $8 million after the company moved nearly $20 million worth of its property out of the jurisdiction, according to a suit filed in state court.

  • October 03, 2024

    Tax Could Help Curtail Plastic Pollution By 2040, OECD Says

    Taxation targeted at plastic use could help to nearly eliminate plastic pollution by 2040 by curbing both creation and consumption, the Organization for Economic Cooperation and Development said.

  • October 03, 2024

    EU, Norway Update VAT Fraud Cooperation Agreement

    The European Union and Norway have amended their agreement on administrative cooperation to help combat value-added tax fraud as well as the recovery of claims, the European Commission announced.

Expert Analysis

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

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