International
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December 16, 2024
Aussie R&D Scheme Promoters Hit With $8.7M In Penalties
The Federal Court of Australia ordered an Australian, his tax agent and his companies to pay a total of AU$13.6 million ($8.7 million) in penalties for promoting illegal research and development tax fraud schemes, the Australian Taxation Office announced.
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December 16, 2024
Canadian Finance Minister Resigns Amid Trump Tariff Threats
Canada's deputy prime minister and minister of finance announced Monday that she is resigning from her post, citing conflicting views with Prime Minister Justin Trudeau about how to respond to tariff threats under President-elect Donald Trump's incoming administration.
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December 16, 2024
Work Still Needed To Keep VAT In EU Effective, Group Says
Following the European Union's agreement on a value-added tax reform package, a group of EU VAT experts presented a wide-ranging suite of short- and long-term proposals Monday aimed at making sure the bloc's regime remains effective as the landscape continues to shift.
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December 16, 2024
Cos. Urge Judge To Maintain Injunction On Transparency Law
A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.
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December 16, 2024
Wyden Bill Would Nix Tax Perks For Private Placement Plans
U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.
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December 16, 2024
HMRC Chief Defends Record On Fighting Tax Evasion
The chief executive of HM Revenue & Customs told Parliament on Monday that the British tax authority has reduced the level of tax noncompliance in response to claims it needs a better strategy on tax evasion.
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December 16, 2024
Info On Over 1,900 Tax Rulings Swapped In OECD Last Year
Tax jurisdictions within the Organization for Economic Cooperation and Development spontaneously shared information related to over 1,900 tax rulings involving foreign companies in 2023, the OECD said Monday, highlighting the widespread adoption of its transparency framework aimed at mitigating harmful tax practices.
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December 16, 2024
Hong Kong Commits To OECD Crypto Reporting Framework
Hong Kong plans to take part in the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets starting in 2028, the jurisdiction's Inland Revenue Department said.
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December 13, 2024
IRS Aims To Ramp Up Partnership Audits, Official Says
The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.
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December 13, 2024
OECD Seeks Input On Ring-Fencing Mining Income Guidance
The Organization for Economic Cooperation and Development said Friday that it is looking for feedback on proposed guidance for tax administrations looking to set up ring-fencing measures for mining operations in order to limit investors' ability to offset expenditures and revenues between projects.
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December 13, 2024
Swiss Gov't Rejects Retroactive Tax On Gifts Above $56M
The Swiss federal government formally rejected a wealth tax proposal by the youth wing of the Social Democratic Party of Switzerland on Friday, saying a retroactive 50% tax on gifts and inheritances above 50 million Swiss francs ($56 million) was "politically questionable."
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December 13, 2024
Canada Must Reassess Tax Bills For Ex-Blue Jays, Court Says
Pension contributions made by two former Major League Baseball stars while they played for the Toronto Blue Jays should be counted in their annual income, the Tax Court of Canada ruled in a victory for the former players.
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December 13, 2024
CFC Tax Issues Can't Be Solved Via Treaties, Officials Say
Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.
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December 13, 2024
IRS Mulls Turning Off Foreign Currency Rules For CFCs
The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.
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December 13, 2024
Halliburton Consistent On Claims For $35M Refund, Court Told
Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.
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December 13, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.
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December 13, 2024
Canada 2-Month Sales Tax Holiday Begins Saturday
A two-month goods-and-services tax holiday in Canada on certain goods such as gifts and restaurant meals will begin Saturday after having passed the Senate and receiving royal ascension.
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December 13, 2024
Contractor Loses Bail For Texting Alleged Tax Cheat Allies
A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.
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December 13, 2024
Loper Bright May Influence Tax Less, IRS Chief Counsel Says
The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.
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December 12, 2024
IRS Wants Choice Retained In Dual Loss Rules, Official Says
The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.
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December 12, 2024
IRS Seeks Feedback On Limits In Previous Taxed Profit Rules
The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.
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December 12, 2024
CJEU Upholds €1.8M Tax On Volvo Group In Belgium
Belgium can impose a "fairness tax" totaling €1.8 million ($1.9 million) on nonresident companies without a permanent office in the country, the Court of Justice of the European Union said Thursday.
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December 12, 2024
2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties
The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.
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December 12, 2024
Swiss To End Credit Offsetting India's Tax Treaty Snub
The Swiss government will no longer offer a credit to taxpayers designed to offset India's rejection of Swiss claims to benefits offered in other Indian tax treaties because India's top court decided to uphold its government's position, according to a notice.
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December 12, 2024
German Fund Managers Charged In €45M Cum-Ex Scheme
Two fund managers have been charged in Germany for "particularly serious" tax evasion over their alleged role in a €45 million ($47 million) cum-ex dividend tax fraud, prosecutors confirmed Thursday.
Expert Analysis
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.