International

  • August 09, 2024

    AI Helped Uncover €185M In Austrian Tax Revenue In 2023

    A special unit in Austria's Ministry of Finance used an artificial intelligence tool to help discover tax fraud cases, generating roughly €185 million ($202 million) in tax revenue in 2023, the ministry said Friday.

  • August 09, 2024

    Bermuda Seeks Comments On Administration Of Minimum Tax

    Bermuda is looking for comments on proposed administrative changes that would accompany its implementation of the OECD's 15% global corporate minimum tax on large multinational entities, including how in-scope businesses will register with the country's new Corporate Income Tax Agency.

  • August 09, 2024

    3 Indicted On Charges Of Leading €93M VAT Fraud Scheme

    Three people suspected of heading a criminal scheme that carried out €93 million ($102 million) in value-added tax fraud involving primarily Apple AirPods have been indicted in Germany, the European Public Prosecutor's Office said Friday.

  • August 09, 2024

    Australia Seeks To Take Pepsi Royalty Tax Fight To Top Court

    The Australian Taxation Office asked the country's top court for permission to appeal a decision that payments between PepsiCo subsidiaries did not qualify for royalty withholding tax or diverted profits tax, according to a news release Friday.

  • August 09, 2024

    What Books Tax Pros Recommend For This Summer

    As practitioners monitor the tax implications of the U.S. presidential election as well as what might come out of the next European Commission, they may want to take a break with a good book. Here, Law360 takes a look at tax specialists' summer reading recommendations.

  • August 09, 2024

    Taxation With Representation: Latham, Freshfields, Wachtell

    In this week's Taxation With Representation, Quantum Capital Group agrees to a roughly $3 billion deal for Cogentrix Energy, Apax Partners LLP is acquiring Thoughtworks for roughly $1.75 billion, and Mallinckrodt inks a $925 million deal for Therakos.

  • August 08, 2024

    Cayman Co. Owes Tax On Partners' Income, Tax Court Says

    A Cayman Islands partnership is liable for withholding taxes on the share of about $24.8 million in income from its U.S. operations that was allocated to its foreign partners through special purpose vehicles, the U.S. Tax Court said Thursday.

  • August 08, 2024

    Judge In HMRC Case Won't Step Aside Over 'Scurrilous' Claim

    A London judge has refused to recuse himself from litigation involving HM Revenue & Customs because of apparent bias and institutional corruption owing to his former connection to the department, finding some of the allegations "frankly scurrilous."

  • August 08, 2024

    Nixon Peabody Hires Community Development Counsel In DC

    When Steven Feenstra, the newest member of Nixon Peabody LLP's the community development finance practice, visited a client's office some 25 years ago, the photos of the community housing projects the client had helped develop made a lasting impression on him, he told Law360 Pulse in an interview Thursday.

  • August 08, 2024

    UK, Ecuador Agree To Double-Tax Treaty

    HM Revenue & Customs published a newly agreed-upon treaty to prevent double taxation between the U.K. and Ecuador on Thursday, which would come into force after approval by both countries' legislatures.

  • August 08, 2024

    Italy Doubles Flat Tax On Nondomiciled To €200K

    Individuals who transfer their tax residence to Italy will now pay a €200,000 ($218,000) flat tax in lieu of other taxes on their foreign income instead of €100,000, the Italian government announced.

  • August 08, 2024

    EU Commission Will Visit Nations To Discuss Capital Markets

    European Commission officials plan to visit member countries beginning in the fall to discuss integrating the European Union's capital markets, which could involve tax law changes, the commission said Thursday.

  • August 08, 2024

    UK Gov't Refunds £57M In Pension Freedoms Overtaxation

    The government has been forced to repay £59.6 million ($75.5 million) in the three months between April and June to people who overpaid tax after they tapped into their pensions for the first time, according to HM Revenue and Customs.

  • August 07, 2024

    Weak Link Doomed $690M Whistleblower Claim, DC Circ. Says

    A whistleblower could not get up to $690 million, or 30% of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program, because the connection between his actions and the program was weak, the D.C. Circuit said Wednesday.

  • August 07, 2024

    EU Seeking Members For Financial Advisory Board

    The European Commission put out a call Wednesday for applications from experts interested in taking over roles on the five-person European Fiscal Board, which advises the commission on certain European Union fiscal operations.

  • August 07, 2024

    Pension Plans' Expert Testimony Limited In $2B Tax Fraud Suit

    A New York federal court decided to exclude portions of an expert's testimony on behalf of pension plans that are accused of seeking to defraud Denmark's tax agency in a $2.1 billion tax refund fraud scheme.

  • August 07, 2024

    UN Economists Want Tax Talks To Address Transparency

    Governments should make tax transparency a top priority for the United Nations framework convention on international tax cooperation and create systems that benefit all countries, the organization's economists said Wednesday.

  • August 07, 2024

    Tax Court's Economic Substance Foray May Clarify Limits

    A U.S. Tax Court judge plans to address an ill-defined provision governing the relevance of the economic substance doctrine in a microcaptive insurance case, offering the courts another chance to clarify an anti-abuse tool the IRS has been deploying more often.

  • August 07, 2024

    Tripling UK's DST Would Cost US Cos. $4.4B, Report Says

    The Liberal Democrats' proposal to raise the U.K.'s digital services tax rate to 6% from 2% would cost U.S. companies up to $4.4 billion a year when accounting for the impact of passing on the costs, a business group said.

  • August 07, 2024

    Singapore's Carbon Tax Is Revenue-Neutral, Minister Says

    Singapore's carbon tax is expected to have a neutral impact on tax revenues over the next decade, even after accounting for a recent hike in the rate to SG$25 ($18.81) per metric ton of emissions, the country's environment minister said.

  • August 07, 2024

    HMRC To Publish More Pillar 2 Draft Guidance

    More guidance is coming for U.K. businesses that will need to comply with the country's implementation of the OECD's Pillar Two global minimum corporate tax rules, HM Revenue & Customs said.

  • August 07, 2024

    Tax On Workers, Families Focus Of Irish Budget, Minister Says

    Ireland's finance minister said Wednesday that a priority of the country's next budget will be addressing the tax burdens of families, workers and businesses, adding that the cost of living remains a serious issue.

  • August 07, 2024

    Lawyer Can't Sue Billionaire Hong Kong Bosses At UK Tribunal

    A lawyer cannot sue a wealthy Hong Kong family in England after she claimed she blew the whistle on potential tax evasion while she worked for them because she was based in the Chinese region while the saga unfolded, a tribunal has ruled.

  • August 06, 2024

    US Wants Israeli Businessman Sanctioned In $3.6M FBAR Suit

    An Israeli businessman should be sanctioned for defying a Washington federal court's discovery orders by a default judgment in the U.S. government's $3.6 million case over his unreported foreign bank accounts and by another order to comply, the government said Tuesday.

  • August 06, 2024

    Wind Tower Co. Asks Full Fed. Circ. To Revisit Subsidy Duties

    A Federal Circuit panel wrongly concluded that a 10% depreciation rate for deducting costs related to manufacturing facilities set by Canadian law was an unfair trade subsidy that justified countervailing trade duties, a wind tower manufacturer told the court in seeking a rehearing.

Expert Analysis

  • 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.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    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.

  • General Counsel Need Data Literacy To Keep Up With AI

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    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.

  • Navigating Discovery Of Generative AI Information

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    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.

  • Finding Focus: Strategies For Attorneys With ADHD

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    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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