International

  • February 27, 2025

    Progress Continues On Amount B, OECD Head Tells G20

    The Organization for Economic Cooperation and Development's work toward a global transfer pricing agreement known as Amount B has made "significant strides" despite the remaining obstacles, OECD Secretary-General Mathias Cormann told Group of 20 finance ministers and central bank governors Thursday.

  • February 27, 2025

    EU Floats Simplifications To Climate Measures To Save €6B

    The European Commission has proposed a set of measures aimed at simplifying the European Union's carbon border adjustment mechanism and other climate provisions to save €6.3 billion ($6.6 billion) in administrative costs and spur €50 billion in additional investments.

  • February 27, 2025

    UK Seeks Input On Plan To Cut Inheritance Tax Farm Relief

    HM Revenue & Customs on Thursday asked for public comments on inheritance tax changes that would cut tax relief available to owners of farmland.

  • February 27, 2025

    Poland Can't Exclude Domestic Funds From Tax Break

    The Polish government can't offer corporate tax exemptions to investment funds managed outside the country unless it offers the same benefits to domestically managed funds, the European Court of Justice ruled Thursday.

  • February 27, 2025

    10 EU Countries Working To Create Tax Dispute Committee

    A group of 10 European Union member countries are working on a multilateral agreement that would establish a permanent committee to settle tax disputes through arbitration, Austria's finance ministry said Thursday.

  • February 27, 2025

    Trader Defends Legitimacy Of £1.4B Tax Refunds In Fraud Trial

    British trader Sanjay Shah and others accused by Denmark's tax authority of involvement in a fraudulent trading scheme to procure billions in tax refunds argued in a London court Thursday that they could not have fraudulently applied for the refunds because they believed the trades were legitimate.

  • February 26, 2025

    Police Supply Store, Others Ask 5th Circ. To Keep CTA Paused

    A Texas police supply store joined with Mississippi libertarians and several other parties asking the Fifth Circuit to keep the Corporate Transparency Act on hold, saying ending the stoppage of that law could force 32 million business entities to file beneficial ownership reports.

  • February 26, 2025

    IRS Spinoff Safe Harbors Not Seen As All-Purpose Reprieve

    Safe harbors proposed by the IRS would allow certain corporate spinoffs to get statutory tax-free treatment, but the bright-line requirements to qualify for these provisions reflect the tension between a blanket approach and the unique complexities of each transaction.

  • February 26, 2025

    Capital Gains Tax Breaks Lack Proof Of Growth, OECD Says

    There is little to no empirical evidence to support the position adopted across most OECD governments that tax relief for capital gains leads to stronger economic growth, broader entrepreneurship and higher savings, the organization said in a report published Wednesday.

  • February 26, 2025

    Billionaire Claims HMRC Failed To Hold Lawful Tax Inquiry

    HM Revenue & Customs failed to lawfully notify the right people in its investigation of tax returns for two partnerships, counsel for a hedge fund billionaire told a London court Wednesday.

  • February 26, 2025

    ATO Moving Fast Against Outlier Tax Debtors, Chief Says

    The Australian Taxation Office is "moving harder and faster" to collect from the 1% of tax debtors who owe about a fifth of the country's roughly AU$50 billion ($31.5 billion) in tax debts, according to prepared remarks by the country's tax commissioner for lawmakers Wednesday.

  • February 26, 2025

    Coke's $2.7B Tax Bill Due To 'Bait And Switch,' 11th Circ. Told

    Coca-Cola urged the Eleventh Circuit to reverse a U.S. Tax Court decision putting the beverage giant on the hook for $2.7 billion in taxes, arguing the ruling excused the IRS' "blatant bait and switch" regarding how it allocates income from foreign affiliates.

  • February 26, 2025

    Tax Overhaul Designer Named Top Tax Adviser To Treasury

    An attorney who worked for Exxon Mobil and helped design the 2017 tax overhaul in President Donald Trump's first term has been appointed to serve as a top tax adviser to Treasury Secretary Scott Bessent, Treasury announced Wednesday.

  • February 25, 2025

    Promised German Tax Cuts Could Come As Deficit Climbs

    With the Christian Democrats, winners of Germany's election, having promised to pursue tax cuts, the country's Ministry of Finance revealed Tuesday that the budget deficit reached €18.7 billion ($19.7 billion) last month.

  • February 25, 2025

    Canada Seeking Feedback On EV Supply Chain Tax Credit

    Canada's government is looking for public input on a plan to introduce a tax credit designed to help support the expansion of electric vehicle manufacturing.

  • February 25, 2025

    Brazil Starts Corp. Tax Compliance Benefit Program

    Companies in Brazil that are up to date and compliant with their tax obligations will be offered benefits for doing so as part of a pilot program, the country's tax service said.

  • February 24, 2025

    Eaton's Foreign Tax Credits Rejected By Tax Court

    The U.S. Tax Court rejected foreign tax credits that Eaton Corp. had claimed on its lower-tier overseas entities' income taxes for 2007 and 2008, saying in a Monday opinion that its overseas ownership structure had disqualified the multinational power management company.

  • February 24, 2025

    Investor Settles In $2.1B Danish Tax Fraud Case

    A U.S. investor who was among those accused by Denmark's tax agency of participating in a $2.1 billion tax fraud scheme related to fraudulently claiming refunds on tax withheld from stock dividends has reached a settlement, according to New York federal court documents filed Monday.

  • February 24, 2025

    Denmark Argues Misrepresentation Led To £1.4B Tax Refunds

    Denmark's tax authority told the High Court of Justice on Monday that it would not have paid out billions in refunds to a British trader and others accused of involvement in a fraudulent trading scheme had they not submitted forms purporting to show eligibility for tax refunds.

  • February 24, 2025

    Ex-Goldman Exec Owes For Not Filing FBARs, US Says

    A former Goldman Sachs banking executive who lives in Australia owes penalties to the Internal Revenue Service for failing to report foreign bank accounts she held, the U.S. government told a D.C. federal court.

  • February 24, 2025

    NZ Reviewing Charity Business Income Tax Exemption

    New Zealand is looking for comments on its internationally unique tax structure that allows charities and not-for-profits to conduct business activities tax-free in order to raise money, asking stakeholders whether such a regime continues to be effective, the country's tax agency said Monday.

  • February 24, 2025

    Apple To Invest $500B In US Over 4 Years As Tariffs Mount

    Apple said Monday that it would invest $500 billion in the U.S. over the next four years, weeks after President Donald Trump placed a 10% tariff on goods from China, where the company sources components for its products, and threatened tariffs on semiconductors.

  • February 24, 2025

    Aussie Tax Office Agrees To Step Up Safeguards For AI

    The Australian Taxation Office said Monday that it will implement seven recommendations made by a national auditing body regarding the agency's adoption of artificial intelligence tools, including looking closer at potential data ethics risks and the overall development of the programs.

  • February 24, 2025

    High Court Won't Hear Tax Tipster's $690M Award Claim

    The U.S. Supreme Court declined on Monday to review a man's claim for a $690 million whistleblower award for undercover recordings and tips he gave the IRS that he said led to the arrests of Swiss bankers and the success of an offshore tax disclosure program.

  • February 24, 2025

    OECD Issues Consolidated Guidance On Amount B

    The OECD issued consolidated guidance Monday that it put out throughout last year for an internationally agreed-upon method to apply the arm's-length principle to pricing baseline marketing and distribution activities by multinational corporations, known as Amount B of Pillar One.

Expert Analysis

  • Lawyers Can Take Action To Honor The Voting Rights Act

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    As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.

  • How To Grow Marketing, Biz Dev Teams In A Tight Market

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    Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.

  • Rock Climbing Makes Me A Better Lawyer

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    Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.

  • Contract Disputes Recap: Preserving Payment Rights

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    Stephanie Magnell and Zachary Jacobson at Seyfarth examine three recent decisions that together illustrate the importance of keeping accurate records and adhering to contractual procedures to avoid inadvertently waiving contractual rights to cost reimbursements or nonroutine payments.

  • Think Like A Lawyer: Dance The Legal Standard Two-Step

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    From rookie brief writers to Chief Justice John Roberts, lawyers should master the legal standard two-step — framing the governing standard at the outset, and clarifying why they meet that standard — which has benefits for both the drafter and reader, says Luke Andrews at Poole Huffman.

  • Lead Like 'Ted Lasso' By Embracing Cognitive Diversity

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    The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.

  • Now More Than Ever, Lawyers Must Exhibit Professionalism

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    As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

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