International
-
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.
-
October 03, 2024
EU Refers 4 Countries To Court Over Pillar 2 Delays
The European Commission said it was referring Cyprus, Poland, Portugal and Spain to the European Union's top court for missing the deadline to implement the global minimum corporate tax, known as Pillar Two.
-
October 02, 2024
BlackBerry's $17M In R&D Not Taxable, Canada Court Rules
BlackBerry Ltd. won't pay taxes on $17.1 million in research and development services it procured from its U.S. affiliates because the services don't fit the definition of foreign accrual property income, the Tax Court of Canada ruled.
-
October 02, 2024
Philippines Enacts 12% VAT On Foreign Digital Services
Google, Amazon and Netflix are among the companies expected to pay a 12% value-added tax on foreign digital service providers that was signed into law Wednesday by Philippines President Ferdinand Marcos Jr., according to government agencies.
-
October 02, 2024
IRS Says European Energy Exchange Is A Qualified Exchange
The European Energy Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Wednesday.
-
October 02, 2024
OECD Releases Crypto Data-Swap Guidance For Tax Agencies
The Organization for Economic Cooperation and Development released guidance Wednesday to help tax administrations automatically exchange information under a new global crypto-asset reporting framework and under an updated system for swapping traditional financial data.
-
October 02, 2024
Mongolia Ratifies OECD Tax Treaty Standards
Mongolia ratified the Organization for Economic Cooperation and Development's multilateral convention on base erosion and profit shifting, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said Wednesday.
-
October 02, 2024
4 Arrested In €97M VAT Fraud Involving Phone Service
Four people were arrested in Italy for their suspected roles in a value-added tax fraud scheme involving services that let users make phone calls via the internet that sought to claim over €97 million ($107 million) in fraudulent refunds, the European Public Prosecutor's Office said Wednesday.
-
October 02, 2024
Canada Finalizes Surtax List For Chinese Steel, Aluminum
Canada's Department of Finance issued its finalized list of Chinese-made steel and aluminum products that will be hit with a 25% surtax when imported into the country starting later this month.
-
October 01, 2024
Tax Deadlines Extended For Victims Of Israel-Hamas War
The Internal Revenue Service said Tuesday that it will postpone tax return and payment deadlines to Sept. 30, 2025, for those affected by the Israel-Hamas war across 2023 and 2024.
-
October 01, 2024
Amgen Must Face Suit It Misled Investors On $10.7B Tax Bill
Amgen lost an attempt to escape a potential class action claiming the pharmaceutical giant hid a $10.7 billion tax bill from investors after a New York federal court ruled there was sufficient evidence for the action to proceed.
-
October 01, 2024
Ex-USTR Official Sees Possible Path Forward For Digital Taxes
The U.S. may withhold trade threats if it believes countries are having good-faith conversations about concerns that their digital services taxes discriminate against U.S. businesses, including in current talks with Canada, the former general counsel for the Office of the U.S. Trade Representative told Law360.
-
October 01, 2024
Ireland Eyes Infrastructure With €14B From ECJ Apple Case
The Irish government is aiming to build infrastructure with the €14.1 billion ($15.6 billion) in corporate tax payments due from Apple Inc. following a European Court of Justice ruling that Ireland granted Apple illegal state aid, officials said Tuesday in announcing next year's budget.
-
October 01, 2024
EU Chief Prosecutor Calls For Making Tax Fraud A Priority
As organized crime rings continue to affect the European Union budget through "massive" value-added tax and customs fraud schemes, more must be done to support the European Public Prosecutor's Office and its power to investigate such crimes, the European chief prosecutor said in remarks published Tuesday.
-
October 01, 2024
Treasury Plans Final Direct Pay Partnership Regs By Year-End
The U.S. Treasury Department is eyeing the end of the year to finalize regulations for development projects to elect out of their partnership tax status to qualify for a direct cash payment of their clean energy tax credits, an official said Tuesday.
-
October 01, 2024
EU General Court To Begin Hearing VAT Cases
The European Union General Court can make preliminary rulings in cases involving the EU's common system of value-added taxes, effective Tuesday, as part of an expansion of the court's jurisdiction.
-
October 01, 2024
UK Tax Havens Tied To $84B In Lost Revenue, Group Says
The British Virgin Islands, Cayman Islands and Bermuda held on to their spots atop the Tax Justice Network's tax havens list, with the group saying Tuesday that the U.K.'s tax havens network is responsible for a third of global corporate tax abuse risks.
-
October 01, 2024
Estate Exaggerating Value Of Exec's Tax Tipoff, DC Circ. Told
A Dutch bank executive's estate is "vastly" overstating the significance of his tips to the IRS in seeking a whistleblower award for his reporting of tax schemes, the U.S. government told the D.C. Circuit, urging it to uphold the U.S. Tax Court's denial of the award.
-
September 30, 2024
Corporate Tax Rates Up In 2023, OECD Annual Report Finds
A global trend toward cutting taxes to address the economics of the COVID-19 pandemic began to wane in 2023, with more nations willing to raise taxes and broaden tax bases to fund social spending, the Organization of Economic Cooperation and Development said Monday.
Expert Analysis
-
The Pop Culture Docket: Judge D'Emic On Moby Grape
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
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
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
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
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
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
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
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
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
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
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
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.
-
1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.