International

  • March 24, 2025

    McDermott Hires Skadden Partner To Lead London Tax Office

    McDermott Will & Emery LLP announced Monday that it has chosen a former Skadden Arps Slate Meagher & Flom LLP partner to serve as the new leader of the firm's U.K. tax office in London.

  • March 24, 2025

    Burden Of Proof Is IRS' For $2.3M Bill, Kyocera Tells Tax Court

    The Internal Revenue Service should bear the burden of proof in making adjustments to an amended return filed by electronics-maker Kyocera, the company argued as it urged the U.S. Tax Court to review an IRS notice saying the company owes $2.3 million for 2018.

  • March 24, 2025

    Caribbean Bank, CEO Accused Of Helping In £415M VAT Fraud

    A Caribbean bank and its former CEO "knowingly" assisted in the commission of a £415 million ($536 million) value-added tax fraud, the creditors of a company allegedly linked to the scam said on the first day of a London trial Monday.

  • March 24, 2025

    TV Star Banned As Co. Director Over Failure To Pay £1M Tax

    A U.K. reality television star has been banned as the director of his media company after it failed to pay more than £1 million ($1.3 million) in taxes, the government's insolvency agency said Monday.

  • March 24, 2025

    FinCEN Exempts US Businesses From Disclosure Rules

    The U.S. Department of the Treasury's financial crimes unit issued interim final rules that exempt domestic businesses from contested reporting regulations, which the department had previously signaled it would narrow to include only foreign companies registered stateside.

  • March 24, 2025

    UK Gov't Considers DST Changes To Prevent US Tariffs

    The Labour government may be considering changes to the digital services tax as part of talks with the U.S. administration to prevent tariffs being imposed on Britain, Chancellor of the Exchequer Rachel Reeves suggested in a TV interview.

  • March 21, 2025

    Court Sours On Tribunal's Sweets Ruling For Marshmallows

    The First-tier Tribunal applied a faulty interpretation of value-added tax law to rule that jumbo-size marshmallows are exempt from VAT, a U.K. Court of Appeal panel said Friday, remanding the £473,000 ($611,000) dispute back to the tribunal.

  • March 21, 2025

    Ex-UBS North America CEO Agrees To $4.9M FBAR Judgment

    The former North American CEO for Swiss bank UBS on Friday agreed to a $4.9 million judgment to end claims that he failed to file timely or accurate foreign bank account reports with the Internal Revenue Service between 2003 and 2013.

  • March 21, 2025

    US-Swiss Agreement Exempts Retirees' Dividends, IRS Says

    U.S. retirement accounts, including trusts, qualified annuity plans and other schemes, are exempt from Swiss taxes on dividends from Swiss companies in which they don't own a controlling interest, according to a U.S.-Switzerland competent authority agreement released Friday by the IRS.

  • March 21, 2025

    Taxation With Representation: Cravath, Paul Weiss, Cooley

    In this week's Taxation With Representation, Google acquires Wiz, QXO Inc. acquires Beacon Roofing Supply, and the Boston Celtics are bought by a group led by private equity firm co-founder William Chisholm.

  • March 21, 2025

    Informal Money Transfers Launder £2B Annually, HMRC Warns

    Criminals in the U.K. are laundering an estimated £2 billion (£2.6 billion) every year via informal money transfer services, HM Revenue and Customs has warned.

  • March 21, 2025

    Spanish Lottery Co. Accused Of Tax Insurance Market Breach

    Spain's competition authority said Friday it is investigating a lottery company on suspicion of suppressing the marketing of tax insurance coverage for lottery winners.

  • March 20, 2025

    Corp. Taxes Should Match Climate Goals, OECD Paper Says

    Countries that want to reduce carbon emissions should design corporate income taxes that align with climate policy objectives, including providing incentives for clean energy investments, according to an OECD working paper released Thursday.

  • March 20, 2025

    Frost Brown Adds Former Houston City Atty To Finance Team

    Frost Brown Todd LLP announced that it has hired an attorney from the ranks of Houston's city government to strengthen its public finance group, adding his expertise in state and local government operations, taxation and economic development.

  • March 20, 2025

    PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.

    Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified.  

  • March 20, 2025

    90% Of Crypto Sellers Conceal Income, Danish Data Shows

    Danish Tax Agency data shows more than 90% of cryptocurrency sellers don't report that income and that many have shifted to foreign platforms to avoid domestic reporting rules, the EU Tax Observatory said in a working paper, suggesting international coordination is essential to tax crypto effectively.

  • March 20, 2025

    Prudential's £9.3M Fees To Silverfleet Taxable, HMRC Argues

    Prudential's payments of £9.3 million ($12 million) to an investment firm are taxable even though the fees were for services the firm carried out when the two companies were part of the same group, the tax authority's counsel told the U.K. Supreme Court on Thursday.

  • March 19, 2025

    IRS Hunter Biden Whistleblower Named Deputy Criminal Chief

    An Internal Revenue Service special agent who accused the U.S. Department of Justice of mishandling an investigation into former President Joe Biden's son has been named deputy chief in the IRS Criminal Investigation division, the agency said Wednesday.

  • March 19, 2025

    Coke's $2.7B Tax Bill Arbitrary, Business Groups Tell 11th Circ.

    Three industry groups asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming that the Internal Revenue Service could raise Coca-Cola's taxes by $2.7 billion, saying in friend-of-the-court briefs that the IRS acted arbitrarily in hiking the Atlanta-based beverage giant's tax liability.

  • March 19, 2025

    Sweden Proposes Cutting Some Green Energy Tax Breaks

    Sweden's Ministry of Finance is proposing that the government slash a pair of green energy tax benefits, one for the installation of solar panels and the other related to the microproduction of renewable energy.

  • March 19, 2025

    Technical, Policy Questions Still Swirl Around Amount B

    U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.

  • March 19, 2025

    DC Judge Won't Preemptively Stop IRS Data Sharing With DHS

    A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their bid for a court order that would preemptively block any information transfer.

  • March 19, 2025

    Switzerland, Zimbabwe Sign Tax Treaty

    Switzerland and Zimbabwe signed an agreement Wednesday for a treaty to avoid double taxation of income, an expansion of the Swiss treaty network in southern Africa that has been welcomed by cantons and businesses, according to Switzerland's competent authority.

  • March 19, 2025

    Law360 Announces The Members Of Its 2025 Editorial Boards

    Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.

  • March 19, 2025

    Group Status Prohibits VAT, Prudential Tells UK Top Court

    Prudential disputed a value-added tax claim on £9.3 million ($12.1 million) in performance fees at the U.K. Supreme Court on Wednesday on the grounds that the business providing the services was a part of the same group as Prudential for tax purposes. 

Expert Analysis

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

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