International
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November 01, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation with Representation, BC Partners sells its majority equity interest in GardaWorld, Lone Star Funds sells specialty chemicals company AOC to Nippon Paint Holdings, Crescent Biopharma takes GlycoMimetics private, and Francisco Partners buys AdvancedMD from Global Payments.
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November 01, 2024
Danish Tax Agency To Settle With Atty In $2.1B Tax Fraud Suit
Denmark's tax authority has agreed to settle with an attorney whom it has accused of helping clients claim fraudulent tax refunds in a sprawling $2.1 billion case, according to a letter by its attorney in New York federal court.
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November 01, 2024
CFC Dividend Tax Issue Brewing In Exams, IRS Official Says
A memorandum from the IRS chief counsel explaining why a controlled foreign corporation cannot claim a 100% deduction for certain foreign-based earnings was necessary to inform field agents dealing with the issue in the exam process, an agency official said Thursday.
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November 01, 2024
Australia Takes In Record AU$98B In Taxes From Big Cos.
Large corporate entities paid a record of nearly AU$98 billion ($64 billion) in income taxes to Australia in the 2022-23 tax year, a 16.7% increase from the previous year, the Australian Taxation Office said.
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November 01, 2024
UK Private Schools Challenging Plan To Charge VAT On Fees
The Independent Schools Council said Friday it plans to contest the government's decision to levy value-added tax on private school fees beginning in January.
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October 31, 2024
Treasury Using Help To Clear Pillar 1 'Logjam,' Official Says
Other executive agencies in President Joe Biden's administration have backed the U.S. Treasury Department in urging negotiators at the Organization for Economic Cooperation and Development to reach a final deal on the international taxing rights overhaul known as Pillar One, a top Treasury official said Thursday.
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October 31, 2024
Australian Tax Collection Up 6% To Nearly AU$611B In 2023-24
Australia collected AU$610.6 billion ($402 billion) in taxes in the 2023-24 tax year, a 6% increase over the year prior and AU$19.4 billion above projections, the Australian Taxation Office said.
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October 31, 2024
OECD Starts Process Of Integrating Thailand As Full Member
The Organization for Economic Cooperation and Development has formally begun the accession process for Thailand to become a full member of the Paris-based body.
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October 31, 2024
Oracle Can't Pause $166M Royalty Cases In Australia
Oracle Corp. can't pause three suits in Australia challenging AU$253.5 million ($167 million) in tax penalties while Irish and Australian authorities conduct a mutual agreement procedure, an Australian judge ruled Thursday, saying a judicial ruling in the cases could affect a wider diplomatic dispute over Australia's royalty taxation.
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October 31, 2024
Scam Promoter Who Cost UK £2.6M In Taxes Is Banned
A man who promoted a tax avoidance scam costing the British government tax agency at least £2.6 million ($3.4 million) has been banned by the government from serving as a director of any company for 10 years, the U.K.'s Insolvency Service announced Thursday.
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October 31, 2024
Exxon Entitled To Interest Deduction On Qatar Deal
Exxon Mobil is entitled to an interest expense deduction on payments to Qatar under a natural gas deal, a Texas federal judge ruled, rejecting the U.S. government's classification of an underlying transaction as a royalty rather than a loan.
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October 31, 2024
Treasury Official Previews M&A Details For Corp. AMT Rules
U.S. rulemakers plan to further address how the country's corporate alternative minimum tax applies to transactions including spinoffs and deals that involve a member of a tax consolidated group, a U.S. Treasury Department official said Thursday.
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October 31, 2024
EU Expected To Close Final Digital VAT Deal Next Week
The European Union is close to a final deal on its plan to bring the bloc's value-added tax rules more in line with the digital economy after representatives reached an agreement in principle, the Hungarian presidency of the Council of the EU confirmed Thursday.
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October 31, 2024
Gov't Urged To Reform Tax Charges On Pension Scam Victims
The government should prioritize reform to ensure that victims of pension scams are no longer hit with massive tax bills, an industry body said Thursday.
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October 31, 2024
5 Convicted In €54M VAT Fraud Of 10,000 Cars
A German court convicted five people for taking part in a value-added tax fraud scheme that involved international trade of more than 10,000 cars that caused €53.7 million ($58.3 million) in estimated losses, the European Public Prosecutor's Office said Thursday.
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October 31, 2024
The 2024 Law360 Pulse Leaderboard
Check out the Law360 Pulse Leaderboard to see which firms made the list of leaders in all-around excellence this year.
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October 31, 2024
Firms' Hiring Strategies Are Evolving In Fight For Top Spot
Competition for top talent among elite law firms shows no signs of slowing down, even amid economic uncertainty, with financially strong firms deploying aggressive strategies to attract and retain skilled professionals to solidify their market position.
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October 31, 2024
11th Circ. Nixes ERISA Claim To John Hancock's $100M Credit
John Hancock Life Insurance Co. had no fiduciary duty to pass on to retirement plans $100 million in foreign tax credits that it had taken from taxes paid on foreign investments, a three-judge panel of the Eleventh Circuit said in upholding a lower court ruling.
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October 31, 2024
Reeves To Face MPs As Budget Enters Approval Process
Chancellor Rachel Reeves is due to be grilled by senior MPs on Nov. 6 after she presented the Labour government's first Budget for 14 years, which features a £40 billion ($52 billion) tax package that has raised concerns of new pressure on businesses and retirement savers.
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October 30, 2024
Jury Finds Importer Didn't Report $17M On Tax Returns
A Los Angeles jury found an importer of Chinese clothing guilty of skirting more than $8 million in customs duties and failing to report more than $17 million in cash transactions on tax returns, federal prosecutors in California announced Wednesday.
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October 30, 2024
Pillar 2 Likely To Cast Shadow Over US Tax Bill Talks
The international minimum tax agreement known as Pillar Two won't officially factor into upcoming tax bill negotiations in the U.S. Congress, but the global regime's potential grab at U.S. tax revenue could informally influence policy choices.
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October 30, 2024
Tax Court Stands By Couple's Tax Liability After Remand
An investor couple whose case was remanded by the Sixth Circuit is still liable for over $603,000 in deficient taxes tied to $3 million in claimed losses from a complex foreign-exchange derivative arrangement since their actions were not made with legitimate intentions of turning a profit, the U.S. Tax Court said Wednesday.
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October 30, 2024
GOP Lawmakers Criticize Treasury's Start Of Taiwan Tax Talks
The top tax-writing Republicans in Congress said Wednesday that the U.S. Treasury Department's announcement that it would begin negotiations with Taiwan on a double-tax relief agreement risks undermining legislation to address the issue that is stalled in the Senate.
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October 30, 2024
Canadian Can't Claim $15.8M In Losses From Forex Trades
A Canadian businessman can't claim CA$22 million ($15.8 million) in losses as deductions because the foreign exchange trades generating them were not pursued for profit, the Tax Court of Canada ruled.
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October 30, 2024
South African Parliament To Consider Global Minimum Tax
Qualifying businesses in South Africa would be subject to two parts of the OECD's 15% global minimum tax on large multinational entities making more than €750 million ($815 million) annually under legislation sent to the country's Parliament on Wednesday.
Expert Analysis
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Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.
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5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.
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How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.
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Litigation Funding Disclosure Key To Open, Impartial Process
Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.
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What NFL Draft Picks Have In Common With Lateral Law Hires
Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.
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Replacing The Stigma Of Menopause With Law Firm Support
A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.
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Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.
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Law Firms Should Move From Reactive To Proactive Marketing
Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.
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The Big Issues A BigLaw Associates' Union Could Address
A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.
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It's Time For A BigLaw Associates' Union
As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.
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How Justices Upended The Administrative Procedure Act
In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.
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Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster
Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.