International
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October 15, 2024
Microsoft's Cost-Share Tax Arguments 'Deficient,' Mich. Says
Microsoft failed to adequately flesh out its arguments that cost-sharing agreement receipts from affiliates should be included in its Michigan apportionment formula as licenses of intellectual property, the state's tax agency argued in asking the Michigan Tax Tribunal to toss the company's case.
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October 15, 2024
Irish Tax-To-GDP Ratio Expected To Drop In 2025
Ireland's tax revenue as a share of its gross domestic product is projected to drop to 25.3% in 2025 as a result of tax measures included in the country's budget proposal, a drop of 3.1 percentage points compared with projections for this year, the country's Department of Finance said Tuesday.
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October 15, 2024
Israel-US Citizen Owes $1.1M In FBAR Penalties, US Says
A dual Israeli-American citizen who owns a Chicago pub faces more than $1 million in penalties for failing to report bank accounts that he maintained in Israel, the U.S. government told an Illinois federal court.
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October 15, 2024
New ABA Tax Chair Wants To Revamp Practice's Dry Image
The new chair of the American Bar Association Section of Taxation told Law360 she wants to boost the section's recent efforts to revamp the tax practice's image as a boring, numbers-intensive profession with limited opportunities to improve society and inspire more students to enter tax law. Here, she shares her background and goals for the tax section.
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October 15, 2024
Alvarez & Marsal Tax Brings On Restructuring Leader
Alvarez & Marsal's tax affiliate added a restructuring professional from investment bank Houlihan Lokey to serve as its head of global restructuring tax services.
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October 15, 2024
Isle Of Man Could Generate £35M Annually From Min. Tax
The Isle of Man's planned implementation of parts of the Organization for Economic Cooperation and Development's global corporate minimum tax on large multinational entities could generate as much as £35 million ($45 million) for the jurisdiction annually, its Treasury said Tuesday.
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October 15, 2024
V&E Adds Energy Tax Pro From Bracewell In Houston
Vinson & Elkins LLP has bolstered its energy transition and tax practices with a partner in Houston who came aboard from Bracewell LLP and whose background includes substantial in-house experience advising on renewable projects.
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October 15, 2024
Starmer Hints At National Insurance Hike Over Capital Gains
British Prime Minister Keir Starmer on Tuesday again refused to rule out raising employers' National Insurance, a payroll levy used to fund social programs, after downplaying claims that his government is planning to raise the capital gains tax.
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October 15, 2024
Law Firms Diverge As Anti-ESG Pushback Continues
A continuing onslaught of legislation and litigation opposing corporate environmental, social and governance actions has created a fork in the road for law firms, with some choosing to scale back efforts and others pushing ahead with their internal ESG and diversity, equity and inclusion goals.
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October 15, 2024
The 2024 Law360 Pulse Social Impact Leaders
Check out our Social Impact Leaders ranking, analysis and interactive graphics to see which firms stand out for their engagement with social responsibility and commitment to pro bono service.
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October 11, 2024
Danish Tax Agency Sniffs Out $367M In VAT Fraud
The Danish Tax Agency said it has issued collections for roughly 2.5 billion Danish kroner ($367 million) since 2018 against companies it discovered were carrying out cross-border value-added tax fraud schemes known as VAT carousels.
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October 11, 2024
France Targets Largest Cos. With Tax In Austerity Budget
The French government said it plans to implement a temporary tax targeting the country's biggest companies as part of a budget of €61.3 billion ($67 billion) of fiscal changes intended to help bring the deficit in line with European Union rules.
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October 11, 2024
Italian Police Freeze €12.3M In Textile VAT Fraud Investigation
The Italian Financial Police carried out two freezing orders totaling €12.3 million ($13.5 million) against suspects in an ongoing investigation into a value-added tax fraud involving the illegal importation of textiles from China, the European Public Prosecutor's Office said.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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How New EU Tax And Transfer Pricing Rules May Affect M&A
Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.
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How Firms Can Ensure Associate Gender Parity Lasts
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.
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7 Common Myths About Lateral Partner Moves
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.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
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.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
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.
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A Post-Mortem Analysis Of Stroock's Demise
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.
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SG's Office Is Case Study To Help Close Legal Gender Gap
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.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
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.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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.
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5 Reasons Associates Shouldn't Take A Job Just For Money
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.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
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.