International

  • September 03, 2024

    NZ Ratifies Slovakia Tax Agreement, Amends Austria Treaty

    New Zealand government ratified a new treaty to avoid double taxation with Slovakia as well as amendments to a previous treaty with Austria, the country's tax agency said.

  • September 03, 2024

    Non-EU Cos. Need Clarity On Public Tax Reporting, Firms Say

    The European Union should clarify how multinational corporations headquartered outside the bloc need to format tax data they report under new public disclosure rules, global accounting firms said.

  • September 03, 2024

    Higher UK Windfall Tax Will Cut Revenue, Says Industry Group

    The U.K. government's plan to raise the energy windfall tax in November may cost HM Treasury around £12 billion ($15.7 billion) in tax revenue, according to an industry group.

  • September 03, 2024

    Norway Seeks Input On Beneficial Ownership Register Access

    Norway's Ministry of Finance is seeking comments on a proposal laying out rules regarding access to the country's beneficial ownership register, the ministry said Tuesday.

  • September 03, 2024

    IRS Issues More Edits For Foreign Currency Accounting Regs

    The Internal Revenue Service issued further corrections Tuesday to proposed rules that would adjust the timing for when companies can use certain accounting methods for gains or losses that arise from foreign currency transactions.

  • August 30, 2024

    Alvarez & Marsal Appoints Tax Experts As Managing Directors

    Alvarez & Marsal Tax LLC appointed tax experts from Anderson and Deloitte as its new managing directors, the firm announced.

  • August 30, 2024

    Danish Gov't Pledges No Ponzi Analogies At $2.1B Tax Trial

    The Danish tax authority won't compare pension funds, investors and attorneys it has accused of defrauding Denmark in a $2.1 billion tax refund scheme to a Ponzi scheme or infamous perpetrator Bernie Madoff, it said Friday in New York federal court.

  • August 30, 2024

    US Seeks Trade Talks In Dispute Over Canada's Digital Tax

    The Office of the U.S. Trade Representative announced Friday that it has requested dispute settlement discussions with Canada regarding the country's recently enacted digital services tax, which the USTR claims discriminates against U.S. companies.

  • August 30, 2024

    Whistleblower Seeks 2nd Bid At $690M Claim In DC Circ.

    A whistleblower denied up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program asked for a D.C. Circuit panel to rehear his case Friday, saying its original opinion included numerous mistakes and misunderstandings.

  • August 30, 2024

    UK's Labour Gov't Urged To Raise Capital Gains Tax

    The Labour government is facing calls to raise the capital gains tax despite financial firms advising investors to sell off their assets or even leave the United Kingdom over the possible tax hike.

  • August 30, 2024

    IRS Corrects Proposed Rules To Address Pillar 2 Losses

    The Internal Revenue Service issued corrections Friday to proposed rules that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.

  • August 30, 2024

    Taxation With Representation: Kirkland, Paul Weiss, Squire

    In this week's Taxation With Representation, Oneok reaches two agreements with energy infrastructure companies worth a total $5.9 billion, McKesson inks a $2.49 billion deal for a cancer center, and First Busey and CrossFirst Bankshares agree to a $917 million merger.

  • August 30, 2024

    Neb. Justices Affirm Nix Of Berkshire Unit's Tax Deduction Bid

    A Nebraska tax deduction for certain dividends doesn't apply to income repatriated under the 2017 federal tax overhaul, the state Supreme Court affirmed Friday in rejecting arguments from a Berkshire Hathaway entity that the state's tax system excluded the foreign earnings from tax.

  • August 29, 2024

    Tax Court Rejects Bid To Change Ruling Post-Chevron

    The U.S. Supreme Court's recent overturning of the Chevron standard of judicial deference to agencies when interpreting statutes does not justify reconsidering a Cayman Islands partnership's tax liability, the U.S. Tax Court ruled.

  • August 29, 2024

    4th Circ. Won't Revive Whistleblower's Credit Suisse Tax Suit

    The Fourth Circuit upheld the dismissal of a former Credit Suisse employee's whistleblower case that alleged the Swiss bank continued to help clients evade taxes after it made a related plea deal with the U.S., saying a 2023 U.S. Supreme Court decision on the False Claims Act could not save the case.

  • August 29, 2024

    Tax Admins Advised To Tailor Structures To Needs Over Time

    Tax administrations must tailor their organization structures to their specific challenges and environments to adapt to modern problems, not just reshuffle organization charts, several international tax groups said Thursday.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • Using A Children's Book Approach In Firm Marketing Content

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    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

  • New Crypto Reporting Will Require Rigorous Recordkeeping

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    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Exploring An Alternative Model Of Litigation Finance

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    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.

  • A Vision For Economic Clerkships In The Legal System

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    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.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    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.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    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.

  • Don't Use The Same Template For Every Client Alert

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    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.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    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.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    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.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    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.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

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    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.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    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.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    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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