International
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August 29, 2024
Day Pitney Lands Former Reuters Tax Counsel In Conn.
Day Pitney LLP continued its recent growth in its tax practice in Connecticut with the addition of an experienced tax attorney from Thomson Reuters.
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August 29, 2024
EU Should Ensure Public Understands Tax Data, Execs Say
The European Union should specify that its disclosure requirements for corporate tax information don't reflect multinational companies' overall operations, a group representing in-house tax practitioners said in comments published Thursday, saying the public could otherwise misunderstand the data.
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August 29, 2024
Brazil Seeks Comments On Transfer Pricing Guidelines
Brazil is seeking public comments on proposed regulations related to its 2023 adoption of new transfer pricing rules, including the application of the international arm's-length standard, the country's revenue agency said Thursday.
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August 29, 2024
UK Reports £300M Rise In Tax Relief To Creative Industries
Creative industries received £2.2 billion ($2.9 billion) in tax relief from the U.K. in the 2022-23 tax year, an increase of £300 million over the prior year largely driven by more claims from high-end TV and theater productions, HM Revenue & Customs said Thursday.
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August 29, 2024
Sky Sports Rugby Pundit Loses Bid To Duck £700K Tax Bill
Rugby commentator Stuart Barnes has lost his attempt to escape a tax bill of almost £700,000 ($921,000) as a tribunal ruled that he owed the money because a contract between his company and Sky was equivalent to an employer-employee relationship.
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August 28, 2024
IRS Declines Watchdog's Ask For Attys In Talks With Big Cos.
The IRS declined a recommendation by its internal watchdog to require the agency's counsel to attend talks held with large multinational corporations by its appellate division, which agents say thwarts their ability to correctly enforce the economic substance doctrine, according to a report.
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August 28, 2024
Feds Looks To Toss Ex-Citizens' Renunciation Fee Challenge
The federal government asked a D.C. federal judge to throw out a lawsuit brought by former U.S. citizens who want their $2,350 citizenship renunciation fee refunded, arguing during a Wednesday hearing that the United States is immune from the litigation and the plaintiffs can't relitigate claims that they already lost.
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August 28, 2024
IRS Corrects Proposed Foreign Currency Accounting Regs
The Internal Revenue Service issued corrections Wednesday to proposed rules that would adjust the timing for when companies could opt to use what is known as the mark-to-market accounting method for gains or losses that arise from foreign currency transactions.
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August 28, 2024
Jury Justified In Dismissing $2.2M FBAR Case, Court Rules
A financial adviser will not face a new trial after an Arizona federal court ruled there was sufficient evidence for a jury to clear him in January of failing to report foreign bank accounts, sparing him at least $2.2 million in penalties.
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August 28, 2024
Sysco, IRS Asked To Address Varian's Foreign Dividend Win
The U.S. Tax Court asked food services giant Sysco and the IRS to address how a tax dispute between them is affected by a recent ruling in a similar case that found medical device company Varian can claim a deduction for foreign dividends.
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August 28, 2024
Treasury To Require Reports On All-Cash Real Estate Deals
Anyone who transfers real estate to a legal entity in an all-cash transaction, including attorneys, will be required starting Dec. 1, 2025, to inform the U.S. Treasury Department about that entity's beneficial owners and their identification numbers under a final rule issued Wednesday.
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August 28, 2024
Greenberg Traurig Builds PE Team With Kirkland Hires
Greenberg Traurig LLP has brought on two fund formation partners from Kirkland & Ellis LLP to continue its growth into the private equity space, according to an announcement this week by the firm.
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August 28, 2024
Taiwan Considering OECD's Global Minimum Tax
Taiwan is looking to implement the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities starting in 2026, the country's Ministry of Finance said Wednesday.
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August 28, 2024
Ireland May Add Timing Flexibility To Dividend Exemption
The Irish government floated more timing flexibility for companies seeking to opt into the country's planned tax exemption for foreign-sourced earnings, but it declined to widen the system's geographical scope.
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August 28, 2024
Atty Can't Escape Danish Tax Agency's $2.1B Tax Fraud Suit
An attorney in a $2.1 billion tax fraud case brought by the Danish tax authority cannot argue that a suit filed against him as an individual should be dismissed because it was filed late, a New York federal court ruled.
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August 27, 2024
Gov't Says Doctor Can't Escape Contempt Fine In FBAR Case
A doctor challenging his $20,000 civil contempt fine for failing to follow a court order to repatriate money from his foreign bank account to cover $1.1 million in tax liabilities shouldn't be allowed to escape the penalty, the U.S. government argued Tuesday.
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August 27, 2024
Canadian Grocery Giant's Bank Wins Appeal Over Tax Credits
The Tax Court of Canada incorrectly decided that a bank owned by the country's largest supermarket chain, Loblaw, couldn't claim tax credits aimed at exempting commercial purchases for payments the bank made in a customer rewards program, a Federal Court of Appeal panel ruled.
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August 27, 2024
OECD Says Malaysia Should Resume GST, End Fuel Subsidies
With spending pressures rising, Malaysia should look to increase its tax revenues through measures including a reintroduction of its goods and services tax, as well as push to minimize its climate impact by eliminating fuel subsidies, the Organization for Economic Cooperation and Development said Tuesday.
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August 27, 2024
Treasury Asked To Scrap Stock Buyback Tax's Funding Rule
Business groups urged the U.S. Treasury Department on Tuesday to remove what's known as the funding rule in forthcoming final regulations on the stock buyback tax, saying the provision would go beyond Congress' intentions for the levy, which aims to deter companies from giving outsize rewards to shareholders.
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August 27, 2024
Croatia, HK, Others Address Hurtful Tax Regimes, OECD Says
Five tax jurisdictions, including Croatia and Hong Kong, have made progress to address various harmful tax practices, the Organization for Economic Cooperation and Development said Tuesday.
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August 27, 2024
Germany Proposes Investment Tax Changes To Attract VC
Germany would adjust its tax laws in an attempt to better attract venture capital and investments into renewable energies under a proposal published Tuesday by the country's finance ministry as part of a planned "growth initiative."
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August 27, 2024
Starmer Warns Of 'Painful' Budget As UK Braces For Tax Hikes
U.K. Prime Minister Keir Starmer warned Tuesday of "painful" decisions to plug budget gaps, including tax increases and spending cuts, looming in the Oct. 30 budget statement.
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August 27, 2024
Gov't Urged To Reform Pension Tax To Fill Budget Gaps
The Labour government should reform £66 billion ($87 billion) worth of pension tax relief to raise extra revenue to help plug the black hole in public finances, a think tank affiliated to the party has said.
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August 26, 2024
Varian Entitled To Foreign Dividend Break, Tax Court Says
California-based medical device company Varian Medical Systems is entitled to a deduction for dividends received from its foreign subsidiaries, the U.S. Tax Court ruled Monday in a unanimous opinion.
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August 26, 2024
US Should Extend Expiring TCJA Tax Cuts, Chamber Says
The expiration of the 2017 Tax Cuts and Jobs Act in 2025 gives the next Congress an opportunity to pass pro-growth tax policies, the U.S. Chamber of Commerce said Monday.
Expert Analysis
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Exploring An Alternative Model Of Litigation Finance
A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.
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A Vision For Economic Clerkships In The Legal System
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.
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A Look At New IRS Rules For Domestically Controlled REITs
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.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
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.
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Don't Use The Same Template For Every Client Alert
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.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
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.
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The Art Of Asking: Leveraging Your Contacts For Referrals
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.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
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.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
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.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
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.
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This Earth Day, Consider How Your Firm Can Go Greener
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.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
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.
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Practicing Law With Parkinson's Disease
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.