International

  • October 11, 2024

    Bird & Bird Adds DLA Piper Legal Director To London Office

    Bird & Bird LLP has added a former DLA Piper legal director as a partner to its London tax team. 

  • October 11, 2024

    Disputes May Loom Over Dividend Deductions For CFCs

    U.S. multinational corporations are concerned that rulemakers' interpretation of a law allowing tax-free repatriation of certain overseas earnings could lead to controversy after the Internal Revenue Service published a memo indicating the break is unavailable for controlled foreign corporations.

  • October 11, 2024

    Fla. Businessman's Estate Faces $2.6M In FBAR Penalties

    A Florida businessman's estate owes the federal government $2.6 million in penalties plus interest for his failure to report his Swiss bank account from 2013 to 2017, the government told a federal court.

  • October 11, 2024

    Taxation With Representation: Davis Polk, Latham, Kirkland

    In this week's Taxation With Representation, Rio Tinto agrees to acquire Arcadium Lithium for roughly $6.7 billion, Ares Management Corp. and GCP International reach a $3.7 billion deal, and Butterfly Equity announces plans to buy The Duckhorn Portfolio for $2 billion.

  • October 10, 2024

    Ukraine's Parliament Hikes Taxes To Fund War With Russia

    Ukraine's Parliament announced that it approved several amendments to the country's tax code Thursday that will raise revenues for its war with Russia.

  • October 10, 2024

    Pillar 2 Carveout Should Cover Some Mobile Items, NFTC Says

    The exemption for tangible investments from the global minimum tax known as Pillar Two should include certain mobile assets, such as ships and aircraft, the National Foreign Trade Council recommended.

  • October 10, 2024

    Ryanair To Scale Back German Flights After Tax Hike

    Irish discount airline Ryanair announced plans Thursday to follow through on its threat to cut back service to Germany next summer over tax issues, saying it will cut 12% of its total capacity in the country — equal to 1.8 million seats — and close three bases of operation.

  • October 10, 2024

    Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says

    Pfizer Inc. is the only company to withhold a country-by-country breakdown of its tax planning in the Senate Finance Committee's probe into how Republicans' 2017 tax package reduced the pharmaceutical industry's U.S. liabilities, according to a letter Chairman Ron Wyden released Thursday.

  • October 10, 2024

    UK Exit Taxes OK When Paid Over Time, Upper Tribunal Says

    An exit tax on U.K. trusts leaving the country pre-Brexit interfered with their European Union right to free movement of capital, but is brought into compliance if trusts can pay the tax over at least a five-year period, the Upper Tribunal ruled.

  • October 10, 2024

    Switzerland Reports Info Exchanges With 108 Jurisdictions

    Switzerland's Federal Tax Administration has exchanged information on roughly 3.7 million financial accounts with 108 jurisdictions so far in 2024, the government said Thursday.

  • October 10, 2024

    Ireland's Finance Bill Sets Out Foreign Dividend Exemption

    The Irish government set out its plans for a new participation tax exemption for foreign dividends as part of a finance bill published Thursday.

  • October 10, 2024

    Algeria Joins OECD Tax Transparency Treaty

    Algeria formally joined the Organization for Economic Cooperation and Development's global tax transparency agreement on combating tax avoidance and evasion by multinational corporations, the OECD announced Thursday.

  • October 09, 2024

    Australia Floats Debt Reduction Creation Rules Guidance

    The Australian Taxation Office published draft guidance Wednesday for the country's new debt deduction creation rules, including the planned compliance approach and a framework for risk assessment.

  • October 09, 2024

    European Parliament Backs Brazil's G20 Wealth Tax Plan

    A majority of the European Parliament supports a 2% minimum tax on billionaires presented by Brazil at the Group of 20 nations meeting, asking the European Union to pursue the topic at the group's November summit, according to joint statements by members of Parliament on Wednesday.

  • October 09, 2024

    Swiss Council Rejects Funding Pensions With Transaction Tax

    Switzerland should not use the revenue generated by its two taxes on financial market transactions to fund the country's pension fund, nor should it create new ones for that purpose, the Swiss Federal Council said Wednesday.

  • October 09, 2024

    OECD Should Clarify Pillar 2 Safe Harbor Timing, CPAs Say

    The OECD should clarify when exactly multinational corporations need to determine whether they qualify for a transitional safe harbor under an international minimum tax agreement, the American Institute of Certified Public Accountants recommended in a letter.

  • October 09, 2024

    UK Gov't Greenlights Film Industry Tax Credit

    U.K. film companies will be able to gain over 50% tax relief for their films' costs from a tax credit approved Wednesday by the Labour government.

  • October 09, 2024

    3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.

    The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.

  • October 09, 2024

    Starmer Refuses To Rule Out Payroll Tax Hike

    Prime Minister Keir Starmer didn't rule out raising employers' National Insurance contributions, a payroll tax used to fund healthcare and state pensions, during Wednesday's question time.

  • October 09, 2024

    Election Uncertainty Hampers Companies' Tax Planning

    With the November election approaching, businesses are bracing for the potential impact of two very different sets of tax policies, with the resulting uncertainty making long-term tax planning increasingly difficult.

  • October 09, 2024

    Australia Seeking Large Cos.'s Tax Execs For Advisory Board

    The Australian Taxation Office is looking for executives in charge of taxes for the country's largest businesses to join an advisory group focused on improving the Australian taxation systems, the ATO said Wednesday.

  • October 09, 2024

    Final Treasury Rules Shut Off Inclusion For Repatriated IP

    The U.S. Treasury Department adopted final rules Wednesday that shut off an annual income inclusion associated with intangibles for companies in certain situations that have transferred intellectual property back to the U.S. from overseas.

  • October 09, 2024

    Gov't Warned Over National Insurance Levy On Pensions

    About half of U.K. employers would scale back the amount they pay into staff pensions to regulatory minimums if a new tax was applied to contributions, according to a survey by a trade group published Wednesday.

  • October 08, 2024

    Germany May Offer Tax Break For 'E-Fuel' Cars, Ministry Says

    The German government will consider a motor vehicle tax exemption for cars running only on fuels manufactured with renewable energy, known as e-fuels-only vehicles, the German Ministry of Finance announced Tuesday.

  • October 08, 2024

    China Pushes Back On Turkish EV Tariffs, Targets EU Brandy

    China said Tuesday that it is appealing to the World Trade Organization to halt Turkish tariffs on electric and hybrid vehicles made in the country, and it announced a temporary anti-dumping measure on European Union brandy that follows the bloc's own EV tariffs.

Expert Analysis

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

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