International

  • October 23, 2024

    EU Tax Nominee Vows Corp. Tax Simplification, Pillar 1 Work

    The nominee to serve as the European Union's next tax commissioner pledged to simplify corporate rules and affirmed his support for the reallocation of taxing rights known as Pillar One in remarks to the European Parliament.

  • October 23, 2024

    ABA Tax Section Pushes IRS To Narrow Pillar 2 Regulations

    Proposed regulations outlining when foreign taxes under the Pillar Two international minimum tax agreement trigger U.S. rules against benefiting twice from the same economic loss should be narrowed to limit their applicability, the American Bar Association Tax Section told the IRS.

  • October 23, 2024

    IRS Grants Tax-Exempt Entities Relief From Corp. AMT Filing

    Tax-exempt entities are not obligated to file the corporate alternative minimum tax form for the 2023 tax year with the Internal Revenue Service, but they should still maintain the document for recordkeeping purposes, the agency announced Wednesday. 

  • October 23, 2024

    EU OKs Swedish Biogas Tax Breaks After Review

    Two Swedish tax exemptions — one for nonfood-based biogas, the other for biopropane used for heating — are in line with European Union state aid rules, the European Commission said Wednesday following a probe into the measures.

  • October 23, 2024

    Judge Threatens To Toss Gov't's $4.9M Son-Of-Boss Claim

    A federal judge warned government attorneys Wednesday that she would dismiss their case against an estate for $4.9 million in taxes if they didn't explain why they weren't actively pursuing their accusations that a Michigan couple schemed to artificially cancel out capital gains

  • October 23, 2024

    Jersey Adopts Global Minimum Tax

    Jersey has adopted the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($808 million) annually, which will take effect in the jurisdiction in 2025.

  • October 23, 2024

    MVP: Sullivan & Cromwell's Eric Wang

    Sullivan & Cromwell's S. Eric Wang advised clients on the tax law implications of major deals over the past year, including a transaction that created the largest gas utility company in North America, earning him a spot as one of the 2024 Law360 2024 Tax MVPs.

  • October 22, 2024

    8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling

    An Eighth Circuit judge cast doubt during oral arguments Tuesday on the government's interpretation of regulations the IRS relied on to reallocate almost $24 million of income to 3M from its Brazilian affiliate that was subject to legal restrictions on royalty payments.

  • October 22, 2024

    New IRS Unit Starts Work On Pass-Through Compliance

    A new Internal Revenue Service unit focused on the compliance of pass-through entities of all sizes and forms, such as partnerships, S corporations and trusts, has officially started work, the agency said Tuesday.

  • October 22, 2024

    Brazil Eyes Shifting Talks On Wealth Taxation To UN

    Brazil is campaigning for the United Nations to commit to creating a minimum tax on high-net-worth individuals in February during expected talks on the organization's burgeoning global tax convention, a Brazilian finance ministry official said Tuesday at the International Monetary Fund.

  • October 22, 2024

    Argentina President Dissolving, Replacing Tax Agency

    Argentina's tax authority, the Federal Public Revenue Administration, will be dissolved and replaced with a new body, the country's president said, with the change causing a 34% reduction in jobs.

  • October 22, 2024

    Tax Court Says It Can't Rule On FBAR Challenge

    The U.S. Tax Court said Tuesday that it lacks the authority to rule on a couple's claim that the Internal Revenue Service wrongly denied them a chance to challenge penalties for failing to report their foreign bank accounts.

  • October 22, 2024

    Wafer Factories Qualify For CHIPS Tax Credit In Final Regs

    Semiconductor wafer production facilities will qualify for the 25% investment tax credit that incentivizes advanced chip manufacturing development projects under final regulations the U.S. Department of the Treasury released Tuesday.

  • October 22, 2024

    IRS Working On Proposed Spinoff Rules, Agency Official Says

    The Internal Revenue Service is planning to propose regulations that may amend positions in an existing revenue procedure that narrowed the range of spinoff transactions the agency will approve as tax-free ahead of time, an IRS official said Tuesday.

  • October 22, 2024

    Winston & Strawn Boosts Transactions Team With NY Tax Atty

    As Winston & Strawn LLP continues to build out its transactions team, the firm has hired a new attorney from Hunton Andrews Kurth LLP with a focus on the tax aspects of real estate financing.

  • October 22, 2024

    Ireland Deposits €4B In Fund Set Up For Tax Surplus

    Ireland transferred €4.05 billion ($4.4 billion) from its Exchequer to one of the sovereign wealth funds it created to invest surplus revenue generated by what the country's Department of Finance has characterized as volatile corporate tax receipts, the department said Tuesday.

  • October 22, 2024

    Portuguese Parliament Passes Min. Tax After EU Pressure

    Portugal would implement the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development under legislation sent to the country's president for approval Tuesday after the European Union put the country on notice for not adopting the tax.

  • October 22, 2024

    How Law Firms Get And Keep Elite Status

    For decades, a handful of New York-based law firms thoroughly dominated the national consciousness when it came to power, profitability and prestige. But in today's legal market, increased movement of partners and clients from one firm to the next has begun to shake things up and create opportunities for go-getters to ascend the ranks.

  • October 22, 2024

    The 2024 Prestige Leaders

    Check out our Prestige Leaders ranking, analysis and interactive graphics to see which firms stand out for their financial performance, attractiveness to attorneys and law students, ability to secure accolades and positive legal news media representation.

  • October 22, 2024

    Director Imprisoned For Concealing £220K Tax Debt

    The former director of a wholesale company has been jailed for 10 months after failing to deliver accounting records when his business went into liquidation owing more than £220,000 ($290,000), the Insolvency Service announced Tuesday.

  • October 22, 2024

    Germany's Sept. Tax Revenue Rises 6.9% Year-On-Year

    Germany's total tax revenue for the month of September reached €86.2 billion ($93.2 billion) after a rise in tax receipts over the summer, an increase of 6.9% year-on-year, the German Ministry of Finance said Tuesday.

  • October 22, 2024

    MVP: Jones Day's Charles 'Chuck' Hodges

    Chuck Hodges, a tax partner with Jones Day, led a gravel company to victory in May at the U.S. Tax Court in a case regarding an $11.1 million sale of a freeway pit, helping him earn a spot as one of the 2024 Law360 Tax MVPs.

  • October 22, 2024

    Budget Fears Spark Surge Of Savers Raiding Pensions

    A third of financial advisers have seen an uptick in customers tapping into their pensions, an investment platform company said, amid speculation the government could reduce the amount that Britons can withdraw without being taxed.

  • October 21, 2024

    BDO Appoints Former HMRC Official, 3 Others To UK Offices

    An HM Revenue & Customs official is among four tax professionals BDO LLP has appointed to its offices in the U.K., the firm announced.

  • October 21, 2024

    Foreign Currency Regs Need Flexibility, Biz Group Says

    The U.S. Treasury Department should allow taxpayers with foreign personal holding companies to get automatic consent to revoke elections on the treatment of foreign currency gains or losses under proposed regulations to align such elections with rules on so-called mark-to-market accounting, the National Foreign Trade Council said.

Expert Analysis

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

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    Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

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