International
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September 05, 2024
Liberty Global Urges 10th Circ. To Grant $248M Tax Credit
The U.S. Tax Court improperly applied an Internal Revenue Code provision to some of the $2.8 billion gain from Liberty Global's sale of a Japanese entity, the telecommunications company said in urging the Tenth Circuit to overturn the resulting rejection of a $248 million tax credit.
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September 05, 2024
Holland & Knight Appoints Former Perkins Coie Tax Partner
Holland & Knight LLP appointed a partner to its Portland, Oregon, office who previously served as a partner in energy tax law for Perkins Coie LLP, the firm announced.
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September 05, 2024
Sen. Finance Panel To Hold Hearing On Tax Policy, Avoidance
The Senate Finance Committee will hold a hearing Sept. 12 covering the 2025 tax policy debate and tax avoidance strategies, it announced Thursday.
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September 05, 2024
Broad, Low-Rate DST May Placate US, Ex-OECD Chief Tells EU
The European Union might be able to break an impasse with the U.S. in negotiations on taxing the digital economy by proposing a digital services tax with a wide base and a low rate, former OECD tax chief Pascal Saint-Amans told Paolo Gentiloni, the bloc's economics commissioner.
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September 05, 2024
UK Extends Startup Investment Tax Incentives Through 2035
Two U.K. tax incentives that encourage private investment in small companies in order to boost innovation and otherwise stimulate economic growth have been extended for 10 years, HM Treasury said.
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September 05, 2024
Tax Pros Want Aussie PM To Halt Code Of Conduct Changes
Six groups representing Australian tax professionals and accountants called on the country's prime minister to step in to stop an "unfair" bill updating the code of conduct for tax agent services if discussions with the country's Treasury don't produce what they say are needed changes.
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September 04, 2024
IRS' Economic Substance Authority Has Limits, Tax Court Told
The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.
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September 04, 2024
New Zealand Looking To Nearly Triple Its Tourist Levy
New Zealand's government is planning to increase a levy on tourists to NZ$100 ($62) per visit, nearly tripling the current rate, according to a joint statement from the country's conservation and tourism ministries.
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September 04, 2024
Irish Tax Surplus Too Reliant On Few Cos., Watchdog Says
It's dangerous for the Irish government to fund long-term plans with corporate tax windfalls pouring into its coffers for over a decade, as three foreign-owned multinational corporations are providing a growing share, risking volatility in an otherwise healthy economy, a parliamentary watchdog said.
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September 04, 2024
Singapore's Annual Corporate Tax Revenue Climbs 26%
Singapore collected SG$80.3 billion ($61.6 billion) in tax revenue in fiscal year 2023-24, a 17% increase over the prior year, thanks in large part to a 25.6% increase in corporate income tax receipts, pushing that total to SG$29 billion, the country's revenue agency said Wednesday.
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September 04, 2024
Swiss To Impose Second Portion Of Pillar 2 Starting In 2025
Switzerland will implement the income inclusion rule portion of the OECD's Pillar Two standards to fight tax base erosion and profit shifting starting in 2025, its Federal Council said Wednesday, complementing its establishment of the 15% global minimum corporate income tax this year.
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September 03, 2024
11th Circ. Trims $12.6M FBAR Fine In 8th Amendment Split
Some of the $12.6 million in penalties the IRS on imposed a man for willfully failing to report foreign bank accounts were in violation of the Eighth Amendment's bar on excessive fines, the Eleventh Circuit ruled, creating an apparent circuit split.
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September 03, 2024
Bahrain Adopting Global Minimum Tax In 2025
Multinational corporations making more than €750 million ($828 million) annually operating in Bahrain will be subject to the OECD's 15% global minimum corporate income tax starting in 2025, the country's tax agency said.
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September 03, 2024
UN Tax Rule On Payments Best For Many Gov'ts, Group Says
Developing countries should seek to add the United Nations' version of a minimum tax rule on payments to their bilateral tax treaties and to adopt corresponding laws domestically while approaching the OECD's more restrictive multilateral version with caution, an advocacy group said Tuesday.
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September 03, 2024
Ex-Defense Contractor Arrested In $350M Tax Evasion Case
A former defense contractor who, with his wife, is facing a 30-count indictment alleging they were involved in a decades-long scheme to defraud the U.S. government and avoid taxes on more than $350 million in income was arrested Tuesday.
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September 03, 2024
NZ Ratifies Slovakia Tax Agreement, Amends Austria Treaty
New Zealand government ratified a new treaty to avoid double taxation with Slovakia as well as amendments to a previous treaty with Austria, the country's tax agency said.
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September 03, 2024
Non-EU Cos. Need Clarity On Public Tax Reporting, Firms Say
The European Union should clarify how multinational corporations headquartered outside the bloc need to format tax data they report under new public disclosure rules, global accounting firms said.
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September 03, 2024
Higher UK Windfall Tax Will Cut Revenue, Says Industry Group
The U.K. government's plan to raise the energy windfall tax in November may cost HM Treasury around £12 billion ($15.7 billion) in tax revenue, according to an industry group.
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September 03, 2024
Norway Seeks Input On Beneficial Ownership Register Access
Norway's Ministry of Finance is seeking comments on a proposal laying out rules regarding access to the country's beneficial ownership register, the ministry said Tuesday.
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September 03, 2024
IRS Issues More Edits For Foreign Currency Accounting Regs
The Internal Revenue Service issued further corrections Tuesday to proposed rules that would adjust the timing for when companies can use certain accounting methods for gains or losses that arise from foreign currency transactions.
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August 30, 2024
Alvarez & Marsal Appoints Tax Experts As Managing Directors
Alvarez & Marsal Tax LLC appointed tax experts from Anderson and Deloitte as its new managing directors, the firm announced.
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August 30, 2024
Danish Gov't Pledges No Ponzi Analogies At $2.1B Tax Trial
The Danish tax authority won't compare pension funds, investors and attorneys it has accused of defrauding Denmark in a $2.1 billion tax refund scheme to a Ponzi scheme or infamous perpetrator Bernie Madoff, it said Friday in New York federal court.
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August 30, 2024
US Seeks Trade Talks In Dispute Over Canada's Digital Tax
The Office of the U.S. Trade Representative announced Friday that it has requested dispute settlement discussions with Canada regarding the country's recently enacted digital services tax, which the USTR claims discriminates against U.S. companies.
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August 30, 2024
Whistleblower Seeks 2nd Bid At $690M Claim In DC Circ.
A whistleblower denied up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program asked for a D.C. Circuit panel to rehear his case Friday, saying its original opinion included numerous mistakes and misunderstandings.
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August 30, 2024
UK's Labour Gov't Urged To Raise Capital Gains Tax
The Labour government is facing calls to raise the capital gains tax despite financial firms advising investors to sell off their assets or even leave the United Kingdom over the possible tax hike.
Expert Analysis
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Recruitment Trends In Emerging Law Firm Frontiers
BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.
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How Associates Can Build A Professional Image
As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.
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Firms Must Rethink How They Train New Lawyers In AI Age
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.
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Think Like A Lawyer: Always Be Closing
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.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
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.
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Lean Into The 'Great Restoration' To Retain Legal Talent
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.
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Fishing Makes Me A Better Lawyer
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.
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A Healthier Legal Industry Starts With Emotional Intelligence
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.
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To Make Your Legal Writing Clear, Emulate A Master Chef
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.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
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.
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Trauma-Informed Legal Approaches For Pro Bono Attorneys
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.
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
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.
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Using A Children's Book Approach In Firm Marketing Content
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.