International

  • June 05, 2024

    EU Corp. Tax Proposal Delayed By Uncertainty On OECD Plan

    European Union countries' negotiations on a proposal to streamline corporate taxation have been delayed because of a lack of clarity on implementation of the OECD's global minimum tax and the design of the accompanying reallocation of taxing rights, a top European Commission tax official said Wednesday.

  • June 05, 2024

    OECD Official Hopes Pillar 2 Ends Some 'Wasteful' Incentives

    The introduction of the global minimum corporate tax known as Pillar Two should lead to the end of some "wasteful" incentives that narrow the tax base, an official from the Organization for Economic Cooperation and Development said Wednesday.

  • June 05, 2024

    Labour's Pension Tax Plans Backed By Fiscal Research Body

    An influential economics think tank has backed plans by the Labour Party to reintroduce the lifetime allowance, arguing that there should be a cap on the tax-free accumulation of pensions wealth.

  • June 04, 2024

    Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties

    A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.

  • June 04, 2024

    Australian Court Upholds Ex-Chinese Citizen's $7.7M Tax Bill

    An Australian court upheld an AU$11.5 million ($7.7 million) tax bill from the Australian Taxation Office to a former Chinese citizen after determining he failed to provide enough evidence to support his alternative tax liability calculation.

  • June 04, 2024

    Calif. OTA Rejects Couple's Claim Of Bolivia Residency

    A California couple owes additional state income tax on a retirement account distribution, the state Office of Tax Appeals said in an opinion released Tuesday, rejecting the pair's assertion that they were domiciled in Bolivia at the time.

  • June 04, 2024

    EU OKs Italian Renewable Energy Plan Funded By Levy

    The European Commission said Tuesday that it approved Italy's plan to introduce a levy on the electricity bills of final consumers to fund construction of renewable energy plants, finding the benefits far outweigh any potential damage to competition and trade.

  • June 04, 2024

    Spain Sends Pillar 2 Bill To Legislature After EU Pressure

    The Spanish government announced Tuesday it has sent a bill to its legislature that would transpose the European Union directive to implement the Organization for Economic Cooperation and Development's global minimum tax on large corporations following pressure from the bloc.

  • June 04, 2024

    New Dutch Gov't Seen Returning To Pro-Biz Positions

    The incoming conservative Dutch government is expected to adopt tax policies that align with the Netherlands' long-standing reputation as a tax-friendly jurisdiction for businesses, in part by reversing a recently enacted measure that taxed companies' purchases of their own shares.

  • June 04, 2024

    Luxembourg Candidate Calls To End EU Tax Unanimity Rule

    The leading Socialist candidate in the upcoming European parliamentary elections said the European Union should scrap the need for unanimity for all tax decisions, clashing with his home country of Luxembourg's longtime stand that's meant to protect its status as a financial center.

  • June 04, 2024

    Austrian Authorities Reveal Spike In Fake Companies

    The number of fake companies in Austria is increasing, according to data from the Finance Ministry, which said that it hoped a new law would aid in combating the trend.

  • June 03, 2024

    Danish Tax Agency Says $2.1B Tax Fraud Suits Not Filed Late

    Denmark's tax administrator urged a New York federal court to reject bids to toss its suits against U.S. pension plans and individuals it accuses of participating in a $2.1 billion fraud scheme, saying the suits were not filed too late.

  • June 03, 2024

    Treasury Aims To Salvage Corp. Transparency Act At 11th Circ.

    The Corporate Transparency Act is a valid exercise of congressional authority to curb money laundering under the commerce clause and the necessary and proper clause in the Constitution, the U.S. Treasury Department told the Eleventh Circuit on Monday in a bid to restore the law's reporting requirements.

  • June 03, 2024

    Tax Convictions Withstand Poor Counsel Claim, 4th Circ. Says

    A North Carolina man's claim of ineffective counsel is not sufficient reason to vacate his convictions for filing false tax returns and obstructing an official proceeding in a case involving $2.1 million in unreported income sent from Bermuda entities, the Fourth Circuit ruled.

  • June 03, 2024

    Texas Oil Co. Says IRS Hasn't Paid $36M Promised Refund

    The Internal Revenue Service has promised to pay a Texas oil company more than $36 million in tax refunds and credits for the 2009 tax year but has failed to do so, the company told a federal court.

  • June 03, 2024

    African Gov'ts Made Big Gains From Data Swaps In 2023

    African tax authorities made huge headway last year in using the international standard for exchange of information on request to find additional revenues of €2.2 billion ($2.4 billion), which is more than over the past 13 years combined, the OECD reported Monday.

  • June 03, 2024

    UK Liberal Democrats Call For Buyback Tax, Tripling DST

    The U.K. Liberal Democrat party called for a 4% share buyback tax on the 100 largest corporations on the stock market as well as for tripling the country's 2% digital services tax, with the additional revenue generated to be earmarked to benefit schoolchildren.

  • June 03, 2024

    South Korea Extending Tax Breaks For Growing Businesses

    Companies in South Korea that graduate from being considered small and medium enterprises to middle-market enterprises will see the grace period that allows them to continue to receive tax breaks granted to smaller entities extended, the country's finance ministry said Monday.

  • June 03, 2024

    7 Arrested In €18M Italian VAT Fraud Ring

    Financial police in Italy arrested seven suspects Monday in connection with a value-added tax fraud scheme involving beverages that resulted in losses of €18 million ($19.6 million), the European Public Prosecutor's Office said.

  • June 03, 2024

    EU Court Asked To Rule On Belgian Tax On Dividends

    A Belgian court asked the European Union's highest court to rule on whether the country can tax dividends transferred from a subsidiary to a parent company, despite an EU law apparently prohibiting this, a document published Monday showed.

  • June 01, 2024

    Blockbuster Summer: 10 Big Issues Justices Still Must Decide

    As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.

  • May 31, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

    Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

  • May 31, 2024

    IRS Guidance Narrows Spinoffs Available For Preapproval

    Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.

  • May 31, 2024

    Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told

    A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.

  • May 31, 2024

    US, Bulgaria Sign Country-By-Country Reporting Agreement

    The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.

Expert Analysis

  • 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.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

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