International

  • December 03, 2024

    Exelon Asks For Corp. AMT To Account For Repairs Deduction

    Power companies should be allowed to account for an industry-specific tax deduction on repair costs to determine whether they're subject to the corporate alternative minimum tax, utility giant Exelon said in a comment letter to the U.S. Treasury Department released Tuesday.

  • December 03, 2024

    Australia Expects Royalties, Reporting Guidance In Early 2025

    The Australian Taxation Office said it expects to release draft guidance in February related to a ruling on when payment agreements for software are considered royalties, followed by guidance for exemptions from its new country-by-country reporting laws in March.

  • December 03, 2024

    Charity's Ex-Partner Gets 10 Years For £1.5M Gift Aid Fraud

    A former finance business partner at national charity Save The Children UK has been jailed for 10 years for stealing £1.5 million ($1.9 million) through fraudulent Gift Aid claims, HM Revenue & Customs announced Tuesday.

  • December 03, 2024

    Comment Deadline Extended For Corp. Alternative Min. Tax

    Treasury and the Internal Revenue Service said Tuesday that they will accept comments on proposed rules for the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more until Jan. 16, a roughly one-month extension from the previous deadline.

  • December 02, 2024

    Russia Looks To 4 FSIA Cases In Bid To Stay $5B Award Suit

    Russia urged a D.C. federal judge to pause a case against it by a Yukos Oil Co. unit seeking to enforce $5 billion in arbitral awards, saying Monday that four parallel Foreign Sovereign Immunities Act cases are pending before the Supreme Court and the D.C. Circuit that could affect the suit.

  • December 02, 2024

    Texas Truck Co. Owes Chinese Tire Import Tax, 5th Circ. Says

    A Houston truck company that sold tires made by a Chinese manufacturer is on the hook for excise taxes as the beneficial owner of the tires, the Fifth Circuit decided in an opinion Monday that reversed a ruling freeing the company from its nearly $2 million tax bill.

  • December 02, 2024

    'Harry Potter' Actor Must Pay £1.8M Tax Bill, Tribunal Says

    Actor Rupert Grint, who portrayed Ron Weasley in the Harry Potter film series, faces a £1.8 million ($2.3 million) tax bill after the U.K.'s First-tier Tribunal ruled that tax avoidance was a primary purpose of an entity created to manage his career.

  • December 02, 2024

    IRS Floats Pooling, Annual Accounting In Offshore Profit Regs

    U.S. multinational companies will be required to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits under proposed rules floated by the U.S. Treasury Department and Internal Revenue Service.

  • December 02, 2024

    A&O Shearman Tax Pro Jumps To Hogan Lovells In DC

    Hogan Lovells said Monday that it has brought on a former Allen Overy Shearman Sterling tax partner who specializes in spinoffs, cross-border deals and other corporate transactions.

  • December 02, 2024

    IRS Finalizes Partnership Liability Regs After 11 Years

    The Internal Revenue Service unveiled final regulations governing the allocation of partnership liabilities 11 years after releasing the proposed rules, saying no subsequent legislative and regulatory changes had taken place to compel the agency to otherwise renew the rulemaking process.

  • December 02, 2024

    Australia Passes Public Country-By-Country Reporting

    Multinational businesses with large operations in Australia are required to publicly disclose information about their operations in tax havens as designated by the government under a country-by-country reporting law that lawmakers adopted following a two-year saga over concerns about the data's confidentiality.

  • December 02, 2024

    Skat Settles With Ex-Barclays Director In £1.4B Fraud Case

    The Danish tax authority has settled its claim against a former Barclays Capital director and four companies that it sued alongside dozens of others over an alleged scheme to defraud it of £1.4 billion ($1.8 billion) in tax revenue.

  • December 02, 2024

    Sports Direct's Ashley Says HMRC Bungled His Data Request

    Sports Direct International PLC founder Michael Ashley argued in a London court Monday that the U.K.'s tax agency improperly handled his data request related to its probe into his 2012 sale of real estate assets, calling its alleged failings "significant, wide-spread and persistent."

  • December 02, 2024

    Australia Seeks Input On Tax Treaty With Portugal

    Australia's Treasury is looking for feedback on plans to implement a treaty with Portugal that would address concerns of double taxation and alleviate cross-border costs by establishing lower withholding rates, the agency said Monday.

  • December 02, 2024

    5 Convicted In €14M COVID Test VAT Fraud Scheme

    A German court convicted five people for their roles in a value-added tax fraud scheme involving the sale of COVID-19 tests that caused about €14 million ($14.7 million) in VAT losses, the European Public Prosecutor's Office said.

  • November 29, 2024

    Audit Watchdog Urges EU To Curb Harmful Tax Practices

    The European Union is still not doing enough to stop harmful corporate tax practices that are costing governments more than €100 billion ($105 billion) a year in revenue, the bloc's independent audit watchdog has warned.

  • November 28, 2024

    Police Detain 32 People In Raids On €297M VAT Fraud Network

    Police have detained more than 30 people in raids on a €297 million ($313 million) value-added tax fraud network that spanned 16 EU countries, the European Public Prosecutor's Office said Thursday.

  • November 28, 2024

    EU Closes Tax Investigations Into Amazon, Fiat, Starbucks

    The European Commission said Thursday that it is closing tax investigations into three multinational companies — Amazon, Fiat and Starbucks — following a series of high-profile court decisions.

  • November 28, 2024

    Ex-HMRC Compliance Officer Helped Husband Launder £3M

    A former compliance officer with HM Revenue and Customs has been handed a suspended sentence for her role in a £3 million ($3.8 million) money laundering operation carried out by her husband, the Crown Prosecution Service has said.

  • November 28, 2024

    AXA Loses Time Limits Appeal In HMRC Foreign Tax Claim

    Insurer AXA has lost its fight over time limits for bringing claims for restitution against the British tax authority over taxes collected in violation of European Union law, as a London appeals court ruled that the limits could not be extended.

  • November 27, 2024

    UN Approves Start Of Formal Talks On Global Tax Convention

    The United Nations General Assembly voted Wednesday in favor of beginning formal negotiations on a global tax convention next year with the goal of finishing in 2027, a proposal that was led by the body's African bloc and won support from 125 countries.

  • November 27, 2024

    US Says Prof's 8th Amendment Argument Fails In FBAR Case

    An 86-year-old former professor cannot claim that his $545,000 penalty for failing to report foreign bank accounts violates the Eighth Amendment, the U.S. told a federal court, saying the penalty is neither excessive nor a fine, and that he never raised the argument before.

  • November 27, 2024

    BlueCrest Disputes 'Disguised Salary' Claim In HMRC Case

    British-American hedge fund BlueCrest Capital Management LLP pushed back Wednesday against arguments from the U.K. tax authority that its portfolio managers are employees receiving a disguised salary.

  • November 27, 2024

    US Seeks FBAR Penalties Over $1.7M In Foreign Accounts

    A Texas woman should face penalties for willfully failing to disclose foreign bank accounts from 2011 through 2013, which held balances exceeding $1.7 million, the U.S. government told a federal court Wednesday.

  • November 27, 2024

    UK Gambling Levy Would Generate £100M, Gov't Says

    A new levy on U.K. gambling operations would generate £100 million ($127 million), which would be earmarked for funding various ways to combat problem gambling, a government agency said Wednesday.

Expert Analysis

  • 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.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.

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