International
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November 18, 2024
6th Circ. Pauses IRS Summons For Eaton Worker Docs
The Sixth Circuit said Eaton Corp. doesn't have to comply with an IRS demand to produce performance reviews for its foreign employees until the appellate court decides whether to overturn a decision that the agency's transfer pricing investigation of the multinational power management company outweighed worker privacy concerns.
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November 18, 2024
Malta Should Work To Align With OECD Min. Tax, IMF Says
Despite its election to delay enacting portions of the OECD's global minimum tax plan under a European Union directive, Malta should develop a plan for adjusting its corporate income tax regime instead of waiting out the clock to implement it, the International Monetary Fund said Monday.
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November 18, 2024
Allen Matkins Adds Stradley Ronon Tax Co-Chair In NY
Allen Matkins Leck Gamble Mallory & Natsis LLP has continued growing its New York office with the addition of the co-chair of Stradley Ronon Stevens & Young LLP's tax department, the firm said Monday.
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November 18, 2024
Poland Enacts Global Min. Tax After EU Pressure
Poland officially implemented the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development following pressure from the European Union to join the majority of the bloc in doing so.
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November 18, 2024
HMRC's £167M Charges To Reuters Group Deemed Lawful
A London court backed HM Revenue & Customs in a case over more than £167 million ($212 million) in diverted profits tax charges issued to U.K. companies in the Thomson Reuters media group.
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November 15, 2024
The Tax Angle: TCJA Debate, S Corp. Compliance
From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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November 15, 2024
OECD Dispute Resolution Caseload Drops For First Time
The number of open dispute resolution cases under the OECD's mutual agreement procedure decreased nearly 4% in 2023, the first time the OECD observed an annual drop in such cases, it said Friday.
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November 15, 2024
Taxation With Representation: Cravath, MoFo, Gibson Dunn
In this week's Taxation With Representation, Cardinal Health takes a majority stake in GI Alliance and acquires Advanced Diabetes Supply Group, Just Eat offloads Grubhub to Wonder Group, Rivian Automotive and Volkswagen Group launch a joint venture, and Ovintiv Inc. buys Montney Basin assets from Paramount Resources Ltd.
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November 15, 2024
Authorities Uncover €5M VAT Fraud Involving Chinese Imports
A European Public Prosecutor's Office investigation uncovered a scheme involving the importation of Chinese textiles into the EU through Greece and headed to the French market that caused an estimated €5.2 million ($5.5 million) in lost value-added taxes and custom duties, the office said Friday.
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November 15, 2024
OECD Tax Forum Commits To Transforming Tax Systems
The OECD's Forum on Tax Administration, made up of representatives from more than 50 tax jurisdictions, agreed to a set of initiatives Friday intended to drive a "transformation" in global tax administration focused on reducing tax gaps and compliance burdens while increasing tax certainty.
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November 15, 2024
Ireland Forecast To Gain Budget Surplus From Apple Case
The Irish government's budget surplus is expected to rise to 4.4% of gross domestic product next year, much of that as a result of the European Court of Justice's ruling against U.S. tech giant Apple, according to an economic forecast published Friday.
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November 14, 2024
Widow Owes $613K After Mexican Tax Dodge, US Tells Court
The widow of a Texas man faces $613,000 in penalties that her husband incurred by failing to report his foreign bank accounts, the U.S. told a federal court, arguing that she participated in a Mexican real estate transaction to avoid paying the penalties he owed.
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November 14, 2024
Australia Delays Country-By-Country Reporting Deadlines
Entities that have country-by-country reporting obligations for the period ending Dec. 31, 2023, received an automatic one-month extension to file such documents, pushing the deadline to the end of January, the Australian Taxation Office said.
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November 14, 2024
IRS Asks Court To Toss Woman's Inheritance Tax Penalty Suit
A woman who missed the deadline for reporting that she received a $350,000 inheritance isn't allowed to sue the IRS for acting arbitrarily in charging her a late penalty because other remedies to her complaint are available to her, the agency told a California federal court Thursday.
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November 14, 2024
Australia Bill Seeks To Expand Rules On Reporting Ownership
Australia's government wants to fight tax avoidance by making owners of equity derivatives disclose significant owners to regulators and investors, expanding access to that information and giving securities regulators new powers to issue freezing orders for noncompliance, the Australian Treasury said Thursday.
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November 14, 2024
OECD Sees Carbon Pricing Growth Coming After Crisis
While the 2022 energy crisis drove down effective carbon excise tax rates and stalled out the percentage of greenhouse gas emissions covered by such taxes or emissions trading systems, the OECD said Thursday that it expects an increase in covered emissions over the next five years.
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November 14, 2024
European Police Detain 43 Suspects In €520M VAT Fraud
European police detained 43 suspects linked to a value-added tax fraud scam valued at €520 million ($550 million) in a cross-border operation against organized crime, law enforcement agencies said Thursday.
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November 13, 2024
South Africa Considering Adjustments To Carbon Tax Regime
South Africa's National Treasury is looking for public comments on proposed adjustments to its carbon tax regime, including cutting the basic tax-free threshold for emissions by more than half over the next decade, it said Wednesday.
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November 13, 2024
$545K FBAR Fine Is Unconstitutional, Ex-Professor Tells Court
An 86-year-old former college professor's penalty of $545,000 for failing to report foreign bank accounts is excessive and violates the Eighth Amendment, he told a California federal court.
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November 13, 2024
90% Of Taxes Paid Online In 48 Jurisdictions, OECD Says
About 90% of all taxes in 48 jurisdictions surveyed by the Organization for Economic Cooperation and Development were paid electronically in 2022, an increase of about 10 percentage points from 2018, the organization said Wednesday.
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November 13, 2024
UK Court Revives $14M Share Of Tax Case Vs. Booze Shipper
The British First-tier Tribunal incorrectly dismissed evidence supporting a more than £11.1 million ($14.1 million) penalty assessment against a businessman accused of alcohol smuggling but was correct to dismiss £22.5 million in related assessments for lack of evidence, the U.K.'s Upper Tribunal ruled.
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November 13, 2024
Norwegian Tax Head Named Vice Chair Of OECD Tax Forum
The director of the Norwegian Tax Administration has been named vice chair of the Organization for Economic Cooperation and Development's Forum on Tax Administration, the Norwegian agency said Wednesday.
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November 13, 2024
NZ Lays Out Tax Work Priorities Aimed At Economic Growth
New Zealand's Inland Revenue Department published overarching priorities Wednesday for the government's work on the country's tax regime in the name of improving the overall economy.
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November 13, 2024
UK Tax Hikes Will Drive Inflation, Industry Group Head Says
The U.K. is set for more price rises in shops as a result of the tax increases in the autumn budget hitting many businesses, the chairman of a retail industry group warned Wednesday.
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November 12, 2024
UK Insurance Co. Entitled To Refund Of Dutch Dividend Tax
A U.K. insurance company is entitled to a refund of taxes levied by the Netherlands on dividends from Dutch companies because the tax restricts the free movement of capital, the Court of Justice of the European Union ruled.
Poor Counsel Led To Unjust Tax Convictions, Justices Told
A North Carolina actuary asked the U.S. Supreme Court to review a Fourth Circuit decision denying his bid to reverse his 2016 tax fraud convictions, saying the ruling was based on bad decisions made by his then-trial counsel.
EC Challenges German Capital Gains Tax In EU High Court
The European Commission said Thursday that it is referring Germany to the Court of Justice of the European Union over the commission's claims that the country's capital gains tax of certain real estate transactions infringes on the free movement of capital.
Trump, GOP Victories May Imperil OECD Global Tax Plan
President-elect Donald Trump's and Republicans' victories in the U.S. elections this month call into question whether the OECD's two-pillar global tax plan can be effectively implemented and whether the plan's minimum tax backstop rule can be applied amid threats of retaliatory tax measures by the U.S.
Poor Counsel Led To Unjust Tax Convictions, Justices Told
A North Carolina actuary asked the U.S. Supreme Court to review a Fourth Circuit decision denying his bid to reverse his 2016 tax fraud convictions, saying the ruling was based on bad decisions made by his then-trial counsel.
EC Challenges German Capital Gains Tax In EU High Court
The European Commission said Thursday that it is referring Germany to the Court of Justice of the European Union over the commission's claims that the country's capital gains tax of certain real estate transactions infringes on the free movement of capital.
Trump, GOP Victories May Imperil OECD Global Tax Plan
President-elect Donald Trump's and Republicans' victories in the U.S. elections this month call into question whether the OECD's two-pillar global tax plan can be effectively implemented and whether the plan's minimum tax backstop rule can be applied amid threats of retaliatory tax measures by the U.S.
Featured Stories
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The Tax Angle: TCJA Debate, S Corp. Compliance
From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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Trump, GOP Victories May Imperil OECD Global Tax Plan
President-elect Donald Trump's and Republicans' victories in the U.S. elections this month call into question whether the OECD's two-pillar global tax plan can be effectively implemented and whether the plan's minimum tax backstop rule can be applied amid threats of retaliatory tax measures by the U.S.
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Trump Victory Boosts GOP Push To Extend 2017 Tax Law
Former President Donald Trump's projected reelection early Wednesday gave GOP lawmakers a strong boost in their efforts to renew major parts of the 2017 tax law that will expire next year, further dimming Democrats' hopes of promoting tax fairness by increasing rates on wealthy corporations and individuals.
Expert Analysis
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
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As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
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Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
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The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
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Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.