International
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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.
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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.
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September 30, 2024
PwC Agrees To $63M Fine For Evergrande Audit, China Says
PwC's chairman agreed to the firm's six-month suspension in China and nearly $63 million in fines over its Chinese auditing arm's work for Evergrande Group, which until a court-ordered liquidation in January was the country's largest real estate firm, the country's Finance Ministry said Monday.
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September 30, 2024
IRS Seeks Input On Draft Partnership Basis-Shifting Form
The Internal Revenue Service asked for comments Monday on a draft form and instructions for partners to disclose all the property they receive from partnerships, part of upcoming regulations meant to target abusive tax avoidance that uses sophisticated partnership basis-shifting transactions.
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September 30, 2024
German Lawyer Charged Over €428M Cum-Ex Fraud
A lawyer has been charged in Germany with several counts of "serious tax evasion" over his alleged role in a €428 million ($477 million) so-called cum-ex dividend tax fraud, a German court confirmed Monday.
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September 30, 2024
Feds Seek Prison In Tax Case Linked To 'China Initiative'
Prosecutors have asked a Texas federal judge for an 18- to 24-month prison sentence for a Chinese-born engineer who pled guilty to tax crimes after being charged with export violations and fraud in a case the defense claims began as an espionage investigation under the U.S. Department of Justice's now-disbanded "China Initiative."
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September 30, 2024
IRS Appeals Office Tests Group Mailbox For Large Cos.
The Internal Revenue Service's Independent Office of Appeals announced Monday that it will test out a program intended to help enhance secure messaging for large businesses with multiple representatives by allowing them to request a group mailbox to communicate with their assigned Appeals employee.
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September 30, 2024
Aussie 2023-24 Budget Delivered Surplus Despite Tax Dip
Australia ended the 2023-24 fiscal year with an AU$15.8 billion ($11 billion) surplus, larger than what the government had projected and primarily due to spending cuts, not higher taxes, according to the country's annual report, published Monday.
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September 27, 2024
Ex-Citizens' Renunciation Fee Suit Shipped To Claims Court
A D.C. federal judge ruled that a lawsuit brought by former U.S. citizens seeking a refund on their $2,350 citizenship renunciation fee belongs in the Court of Federal Claims.
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September 27, 2024
Constitution Permits Blocked Anti-Laundering Law, Panel Told
The U.S. government urged the Eleventh Circuit on Friday to reinstate the Corporate Transparency Act passed in 2021, arguing that the anti-money laundering law is within Congress' powers to regulate economic activity and necessary to have businesses report beneficial ownership to combat crimes like tax evasion and terrorist financing.
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September 27, 2024
IRS Plans Transition Rules In Basis-Shifting Regs, Atty Says
The IRS plans to include transition rules in forthcoming proposed regulations that aim to clamp down on abusive tax avoidance practices through complex partnership transactions known as basis shifting, an agency attorney said Friday.
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September 27, 2024
Corp. AMT Rules Could Wrap In Smaller Partnerships
Recently proposed rules on the U.S. corporate alternative minimum tax create new concerns for partnerships of various sizes that could be forced to comply with complex reporting requirements unless the government introduces carveouts, tax observers said.
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September 27, 2024
Ireland Seeks Input On Business Interest Tax Regime
Ireland has asked for comments on its business interest taxation and deduction regime, as well as whether the country should introduce a commercial business purposes test for deductions, its government said Friday.
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September 27, 2024
Taxation With Representation: Kirkland, Skadden, Cleary
In this week's Taxation With Representation, Blackstone and Vista Equity Partners acquire Smartsheet Inc., Macquarie Asset Management takes a stake in D.E. Shaw Renewables Investment Group, and Apogee Enterprises Inc. buys UW Interco LLC from Heartwood Partners.
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September 27, 2024
US Trade Group Pushes OECD On Compliance Burden
The Organization for Economic Cooperation and Development needs to do more work on the safe harbor provisions of its Pillar Two 15% global corporate minimum tax plan — including potentially making it permanent — among other compliance burden concerns, the National Foreign Trade Council said Friday.
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September 27, 2024
Gov't Could Target Pension Contributions In Tax Raid
The U.K. government could introduce a new levy on employer pension contributions as a means of plugging a £22 billion ($29.5 billion) black hole in public finances, experts said Friday.
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September 26, 2024
Belgian Co. Can't Keep Using Ad Space Rent-Free, ECJ Says
The European Court of Justice on Thursday upheld a 2019 European Commission ruling that a street furniture company's owed rent for Brussels bus shelter advertising space, agreeing with the commission that allowing the company to continue using the ad displays without paying rent or taxes constituted unlawful state aid.
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September 26, 2024
Tribunal Halts $52.8M German Tax Collection Against Oil Cos.
German tax authorities shouldn't collect a windfall profits tax totaling at least €47.2 million ($52.8 million) from two oil refineries before the dispute has been litigated, a tribunal of the International Centre for Settlement of Investment Disputes said.
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September 26, 2024
Montreal Exchange Is A Qualified Exchange, IRS Says
The Montreal 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 Thursday.
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September 26, 2024
Amazon Reports Paying £932M In UK Taxes In 2023
Amazon said Thursday that it paid a total of £932 million ($1.25 billion) in U.K. taxes last year, which the company said puts it among the 10 largest taxpayers in the country.
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September 26, 2024
Tariff Tax Base Too Small To Replace Income Tax, Report Says
Higher tariffs can't replace income tax revenue, as former President Donald Trump has suggested, since U.S. imports total $3 trillion annually while incomes top $20 trillion, but they would lower incomes by raising prices for U.S. consumers, a think tank reported Thursday.
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September 26, 2024
Irish Dividend Exemption Too Restrictive, Big 4 Say
The Big Four accounting firms raised concerns about wording in Ireland's planned tax exemption for foreign-sourced dividends, claiming in comments released Thursday that it would be overly restrictive to require dividends to come solely out of an offshore affiliate's profits.
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September 26, 2024
Harris' And Trump's Tax Plans Each Add To Deficit, Study Says
The U.S. federal deficit would grow by at least $2 trillion over the next decade from the tax policy plans of both major parties' candidates, former President Donald Trump and Vice President Kamala Harris, researchers said Thursday.
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September 26, 2024
UK Cos. Claimed Nearly £1.5B In Patent Box Relief In 2022-23
While there was a slight dip in the number of U.K. companies that elected to use the country's patent box tax regime in the 2022-23 tax year compared with the prior year, the estimated value of relief claimed jumped to nearly £1.47 billion ($1.97 billion) compared with around £1.33 billion, HM Revenue & Customs said Thursday.
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September 26, 2024
UK R&D Tax Credit Claims Down, But Total Relief Up £100M
While there was an over 20% dip in research and development tax credit claims in the U.K. in the 2022-23 tax year, the total relief claimed rose to £7.5 billion ($10.1 billion), a £100 million increase, HM Revenue & Customs said Thursday.
Expert Analysis
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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Tips For Litigating Against Pro Se Parties In Complex Disputes
Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.