International

  • April 17, 2024

    Canada Proposes Top-End Tier To Boost Capital Gains Tax

    Canada's government is seeking to introduce a new tier to its capital gains tax regime, increasing the portion of gains on which tax is paid to two-thirds from the current 50% for any capital gains more than CA$250,000 ($182,000).

  • April 17, 2024

    Judge Delays Trial Over $20M Allegedly Hidden From IRS

    A Florida federal judge agreed Wednesday to delay the trial of a Brazilian-American businessman accused of hiding $20 million from the Internal Revenue Service by using Swiss bank accounts, but told the defendant the new deadlines are firm.

  • April 17, 2024

    Loeb & Loeb Adds 2 Corporate Partners From Morrison Cohen

    Loeb & Loeb LLP has announced the latest in a string of corporate hires from Morrison Cohen LLP's ranks, touting two new partners with domestic and international experience with strategic transactions.

  • April 17, 2024

    Tax Incentives Needed To Boost EU Investments, Adviser Says

    European Union countries must give tax incentives to boost long-term savings plans for individuals and institutions in an effort to gather capital for investment in businesses, a top adviser said Wednesday.

  • April 17, 2024

    EU To Start Review Of Disclosure Laws In May, Official Says

    The European Commission plans to launch a review of some parts of its landmark tax disclosure legislation in May, a senior tax official said Wednesday, suggesting the body is open to simplifying the law.

  • April 17, 2024

    Swedish Bank Tax Not A State Aid Violation, EU Court Affirms

    A Swedish banking tax does not run afoul of the European Union's rules on state aid, the EU's lower court said Wednesday, dismissing a bid by the country's banking lobby to annul the European Commission's approval of the measure.

  • April 16, 2024

    Corp. Transparency Act A Valid Use Of Powers, 11th Circ. Told

    The U.S. Department of Treasury told the Eleventh Circuit that a federal district court erred in finding the Corporate Transparency Act unconstitutional, saying the lower court misunderstood the law's scope and relation to efforts to curb financial crime.

  • April 16, 2024

    Canada Expects Digital Tax To Increase Revenue By CA$5.9B

    Canada's proposed digital services tax is estimated to bring in CA$5.9 billion ($4.3 billion) over five years, according to the country's 2024 budget, which was released Tuesday and cited continued international delays in implementing a worldwide profit reallocation agreement.

  • April 16, 2024

    Veteran's Signature On IRS Doc Not Forged, Tax Court Finds

    U.S. Air Force veteran and his wife failed to convince the U.S. Tax Court on Tuesday that their signatures were forged on an agreement to pay federal income taxes while working in Australia for defense contractor Raytheon.

  • April 16, 2024

    3 Key Takeaways From The IRS' Latest Pricing Pact Snapshot

    The IRS finalized a record number of advance pricing agreements in 2023, signaling the agency's increased effectiveness at completing accords at a time when its approach to transfer pricing litigation could fuel corporate taxpayers' urgency for seeking APAs. Here, Law360 breaks down three key takeaways from the agency’s latest APA report.

  • April 16, 2024

    Orrick Adds Former Hogan Lovells Atty To German Tax Group

    Orrick Herrington & Sutcliffe LLP added a former Hogan Lovells counsel to its German tax group, the firm announced.

  • April 16, 2024

    McDermott Hires 2 Partners For Global Tax Practice In Paris

    McDermott Will & Emery is expanding its global tax practice group with two partners in Paris who have a track record of advising on cross-border mergers and acquisitions and tax controversies before France's tax authority, the firm announced. 

  • April 16, 2024

    Finland's Boost In Financial Crimes Led To $156M In Damage

    A record nearly 2,400 financial crimes reported to Finland's authorities in 2023 — with 54% of them debtor crimes and tax and accounting crimes — resulted in €147 million ($156 million) in criminal damage, the Finnish Tax Administration said Tuesday.

  • April 16, 2024

    Global Economic Growth To Remain Slow, Steady, IMF Says

    The global economy has been "surprisingly resilient" in its bounce back from widespread troubles, leading to projections of a slow but steady 3.2% growth continuing through this year and the next, the International Monetary Fund said in its annual report Tuesday.

  • April 16, 2024

    Treasury Gains £12B Fiscal Headroom In New Tax Year

    HM Treasury may have an extra £12 billion ($14.9 billion) to spend this financial year started April 6 thanks to the government's fiscal rule to cut national debt by 2029, the Institute for Fiscal Studies said in a report Tuesday.

  • April 16, 2024

    Taylor Wessing Launches Ireland Tax Practice With New Hire

    Taylor Wessing LLP has recruited its first tax partner in Ireland from Simmons & Simmons LLP to launch a new tax group in the country, continuing its expansion after initially setting up shop in Dublin three years ago.

  • April 16, 2024

    EU Leaders Expected To Clash Over Corp. Tax Harmonization

    European Union leaders are expected to clash at their summit Wednesday and Thursday over whether national corporate taxes should be harmonized to promote equity investments, an official from the bloc said Tuesday.

  • April 15, 2024

    Exxon Seeks $1.8B Tax Refund As Qatar Deal Trial Opens

    Exxon Mobil Corp. argued Monday in Texas federal court that its deal with Qatar to extract natural gas from the country's coast was a partnership, rather than a lease agreement, saying at the start of a trial that it's entitled to get $1.8 billion in tax benefits back from the IRS.

  • April 15, 2024

    House OKs Ending Exemption For Terrorist-Supporting Orgs

    The House passed legislation Monday that would authorize the Internal Revenue Service to suspend the tax-exempt status of any nonprofit organization found by the U.S. Treasury secretary to support foreign terrorism.

  • April 15, 2024

    8th Circ. Urged To Revive IRS' Pricing For Medtronic

    The U.S. government urged the Eighth Circuit on Monday to side with the IRS' method for pricing the intangible property that medical device maker Medtronic licensed to a Puerto Rican affiliate, arguing it's the only way to determine arm's-length royalty rates.

  • April 15, 2024

    EU Seeking Input On Tax Cooperation Program's Progress

    The European Commission is looking for input from the tax administrations of the European Union and cooperating countries on the efficacy of a program meant to aid in the fight against tax fraud, tax evasion and aggressive tax planning, it said Monday.

  • April 15, 2024

    Accounting Ethics Board Issues Int'l Tax Planning Standards

    A global accounting ethics board issued Monday what it says is the first comprehensive suite of global standards on ethical considerations in tax planning and related services in hopes of restoring public trust in accounting firms and corporations.

  • April 15, 2024

    HMRC Maintaining VAT Policies After EU Law Decoupling

    The interpretation of the U.K.'s value-added tax and excise tax regimes have remained the same despite the removal of the supremacy of the European Union's laws at the beginning of the year, HM Revenue & Customs said Monday.

  • April 15, 2024

    More EU Cooperation Needed Against VAT Fraud, Official Says

    The €11 billion ($11.7 billion) in value-added tax fraud uncovered in 2023 by the European Union's prosecution office is probably "only the tip of an iceberg" and should prompt countries to intensify joint cooperation, the office's top official said.

  • April 12, 2024

    FedEx Not Entitled To $84.6M In Tax Credit Dispute, US Says

    FedEx is not entitled to a judgment of nearly $84.6 million that the company requested in March for its foreign tax credit dispute, the federal government said Friday in a Tennessee federal court filing.

Expert Analysis

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

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