International

  • November 18, 2024

    HMRC's £167M Charges To Reuters Group Deemed Lawful

    A London court backed HM Revenue & Customs in a case over more than £167 million ($212 million) in diverted profits tax charges issued to U.K. companies in the Thomson Reuters media group.

  • November 15, 2024

    The Tax Angle: TCJA Debate, S Corp. Compliance

    From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • November 15, 2024

    Poor Counsel Led To Unjust Tax Convictions, Justices Told

    A North Carolina actuary asked the U.S. Supreme Court to review a Fourth Circuit decision denying his bid to reverse his 2016 tax fraud convictions, saying the ruling was based on bad decisions made by his then-trial counsel.

  • November 15, 2024

    OECD Dispute Resolution Caseload Drops For First Time

    The number of open dispute resolution cases under the OECD's mutual agreement procedure decreased nearly 4% in 2023, the first time the OECD observed an annual drop in such cases, it said Friday.

  • November 15, 2024

    Taxation With Representation: Cravath, MoFo, Gibson Dunn

    In this week's Taxation With Representation, Cardinal Health takes a majority stake in GI Alliance and acquires Advanced Diabetes Supply Group, Just Eat offloads Grubhub to Wonder Group, Rivian Automotive and Volkswagen Group launch a joint venture, and Ovintiv Inc. buys Montney Basin assets from Paramount Resources Ltd.

  • November 15, 2024

    Authorities Uncover €5M VAT Fraud Involving Chinese Imports

    A European Public Prosecutor's Office investigation uncovered a scheme involving the importation of Chinese textiles into the EU through Greece and headed to the French market that caused an estimated €5.2 million ($5.5 million) in lost value-added taxes and custom duties, the office said Friday.

  • November 15, 2024

    OECD Tax Forum Commits To Transforming Tax Systems

    The OECD's Forum on Tax Administration, made up of representatives from more than 50 tax jurisdictions, agreed to a set of initiatives Friday intended to drive a "transformation" in global tax administration focused on reducing tax gaps and compliance burdens while increasing tax certainty.

  • November 15, 2024

    Ireland Forecast To Gain Budget Surplus From Apple Case

    The Irish government's budget surplus is expected to rise to 4.4% of gross domestic product next year, much of that as a result of the European Court of Justice's ruling against U.S. tech giant Apple, according to an economic forecast published Friday.

  • November 14, 2024

    Widow Owes $613K After Mexican Tax Dodge, US Tells Court

    The widow of a Texas man faces $613,000 in penalties that her husband incurred by failing to report his foreign bank accounts, the U.S. told a federal court, arguing that she participated in a Mexican real estate transaction to avoid paying the penalties he owed.

  • November 14, 2024

    Australia Delays Country-By-Country Reporting Deadlines

    Entities that have country-by-country reporting obligations for the period ending Dec. 31, 2023, received an automatic one-month extension to file such documents, pushing the deadline to the end of January, the Australian Taxation Office said.

  • November 14, 2024

    IRS Asks Court To Toss Woman's Inheritance Tax Penalty Suit

    A woman who missed the deadline for reporting that she received a $350,000 inheritance isn't allowed to sue the IRS for acting arbitrarily in charging her a late penalty because other remedies to her complaint are available to her, the agency told a California federal court Thursday.

  • November 14, 2024

    Australia Bill Seeks To Expand Rules On Reporting Ownership

    Australia's government wants to fight tax avoidance by making owners of equity derivatives disclose significant owners to regulators and investors, expanding access to that information and giving securities regulators new powers to issue freezing orders for noncompliance, the Australian Treasury said Thursday.

  • November 14, 2024

    OECD Sees Carbon Pricing Growth Coming After Crisis

    While the 2022 energy crisis drove down effective carbon excise tax rates and stalled out the percentage of greenhouse gas emissions covered by such taxes or emissions trading systems, the OECD said Thursday that it expects an increase in covered emissions over the next five years.

  • November 14, 2024

    EC Challenges German Capital Gains Tax In EU High Court

    The European Commission said Thursday that it is referring Germany to the Court of Justice of the European Union over the commission's claims that the country's capital gains tax of certain real estate transactions infringes on the free movement of capital.

  • November 14, 2024

    European Police Detain 43 Suspects In €520M VAT Fraud

    European police detained 43 suspects linked to a value-added tax fraud scam valued at €520 million ($550 million) in a cross-border operation against organized crime, law enforcement agencies said Thursday.

  • November 13, 2024

    South Africa Considering Adjustments To Carbon Tax Regime

    South Africa's National Treasury is looking for public comments on proposed adjustments to its carbon tax regime, including cutting the basic tax-free threshold for emissions by more than half over the next decade, it said Wednesday.

  • November 13, 2024

    $545K FBAR Fine Is Unconstitutional, Ex-Professor Tells Court

    An 86-year-old former college professor's penalty of $545,000 for failing to report foreign bank accounts is excessive and violates the Eighth Amendment, he told a California federal court.

  • November 13, 2024

    90% Of Taxes Paid Online In 48 Jurisdictions, OECD Says

    About 90% of all taxes in 48 jurisdictions surveyed by the Organization for Economic Cooperation and Development were paid electronically in 2022, an increase of about 10 percentage points from 2018, the organization said Wednesday.

  • November 13, 2024

    UK Court Revives $14M Share Of Tax Case Vs. Booze Shipper

    The British First-tier Tribunal incorrectly dismissed evidence supporting a more than £11.1 million ($14.1 million) penalty assessment against a businessman accused of alcohol smuggling but was correct to dismiss £22.5 million in related assessments for lack of evidence, the U.K.'s Upper Tribunal ruled. 

  • November 13, 2024

    Norwegian Tax Head Named Vice Chair Of OECD Tax Forum

    The director of the Norwegian Tax Administration has been named vice chair of the Organization for Economic Cooperation and Development's Forum on Tax Administration, the Norwegian agency said Wednesday.

  • November 13, 2024

    NZ Lays Out Tax Work Priorities Aimed At Economic Growth

    New Zealand's Inland Revenue Department published overarching priorities Wednesday for the government's work on the country's tax regime in the name of improving the overall economy.

  • November 13, 2024

    Trump, GOP Victories May Imperil OECD Global Tax Plan

    President-elect Donald Trump's and Republicans' victories in the U.S. elections this month call into question whether the OECD's two-pillar global tax plan can be effectively implemented and whether the plan's minimum tax backstop rule can be applied amid threats of retaliatory tax measures by the U.S.

  • November 13, 2024

    UK Tax Hikes Will Drive Inflation, Industry Group Head Says

    The U.K. is set for more price rises in shops as a result of the tax increases in the autumn budget hitting many businesses, the chairman of a retail industry group warned Wednesday.

  • November 12, 2024

    UK Insurance Co. Entitled To Refund Of Dutch Dividend Tax

    A U.K. insurance company is entitled to a refund of taxes levied by the Netherlands on dividends from Dutch companies because the tax restricts the free movement of capital, the Court of Justice of the European Union ruled.

  • November 12, 2024

    Treasury's Energy Tax Perk Regs On Track Despite Trump Win

    The U.S. Treasury Department still plans to finalize remaining clean energy tax credit regulations by the end of this year despite President-elect Donald Trump's campaign promise to unravel the 2022 climate law that enacted them, a Treasury spokesperson told Law360 on Tuesday.

Expert Analysis

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    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.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    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.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    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.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    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.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    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.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    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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