International
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May 24, 2024
Court Upholds Limit To Award In Ecopetrol, Texas Co. Dispute
An arbitration tribunal was within its authority to limit the number of years and the amount that a Houston-based oil company had to reimburse Colombia's state-owned entity, Ecopetrol, for the value-added tax liability of a subsidiary while owned by the company, a New York federal judge determined.
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May 24, 2024
CohnReznick Adds Tax Planning Partner From Mazars
CohnReznick LLP added a top accountant and tax partner from Mazars USA LLP to its roster of tax professionals, the firm announced.
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May 24, 2024
Global Minimum Tax Should Be Tied To Inflation, Report Says
The €750 million ($814 million) annual revenue threshold for businesses to be considered in scope of the OECD's global corporate minimum tax should be indexed to inflation to protect businesses from being wrongly forced to comply, a think tank report said.
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May 24, 2024
UK Calls On Belarus To Undo Suspension Of Tax Agreement
The U.K. is demanding that Belarus reverse a council resolution that suspends provisions of the double-taxation agreement between the two countries starting June 1, according to a statement released by HM Revenue & Customs.
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May 24, 2024
IRS Corrects Notice On Bonus Energy Tax Credit Safe Harbors
The Internal Revenue Service and U.S. Department of the Treasury issued a correction Friday to a notice providing additional safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts.
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May 24, 2024
€14M VAT Fraud Scheme In Belgium, Netherlands Busted
Seven people were arrested in the Netherlands in connection to a value-added tax fraud scheme involving the Belgian subsidiary of a Dutch company fraudulently claiming a €13.7 million ($14.9 million) refund on trades of goods that never happened, the European Public Prosecutor's Office said Friday.
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May 24, 2024
Taxation With Representation: Davis Polk, Wachtell, Latham
In this week's Taxation With Representation, SouthState Corp. buys Independent Bank Group Inc., CyberArk acquires Venafi, Carlyle clinches its fifth Japanese buyout fund, and AuditBoard Inc. agrees to be bought by Hg Capital.
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May 24, 2024
Cyprus, Portugal Aim For National Implementation Of Pillar 2
Cyprus and Portugal both said Friday that they are moving toward putting the minimum tax known as Pillar Two into their national legislation, which EU law requires them to have done by the end of 2023.
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May 23, 2024
Premier League Team Goes Down 2-Nil In VAT Bill Appeal
Premier League soccer team Nottingham Forest must pay its more than £345,000 ($438,000) value-added tax bill, the U.K.'s Upper Tribunal ruled in a decision published Thursday, dismissing an appeal of a lower court ruling that found HM Revenue & Customs filed its tax assessment on time.
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May 23, 2024
Italy Adopts Safe Harbor Global Minimum Tax Rules
Italy has added a temporary safe harbor provision to its implementation of the Organization for Economic Cooperation and Development's global minimum tax to ease the transition for in-scope companies, the country's finance ministry said.
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May 23, 2024
White & Case Adds Former A&O Tax Pro In Luxembourg
White & Case LLP announced it has added a tax partner to its Luxembourg office from A&O Shearman who specializes in international and Luxembourg corporate tax law.
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May 23, 2024
Carbon Pricing Generated Over $100B In 2023, Report Says
Carbon pricing mechanisms worldwide generated a record $104 billion in revenue in 2023, according to a World Bank report, though it said the 75 instruments currently in force are too few and doing too little.
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May 23, 2024
Spain, Greece, Sweden Have Tax Policy Problems, EU Says
The European Union's executive arm called on Spain, Greece and Sweden on Thursday to change tax laws the bloc finds problematic, while also referring a Spanish tax issue to the European Court of Justice.
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May 23, 2024
EU Flags Nations For Shortcomings On Pillar 2, Exchange Law
The European Commission said Thursday that six European Union countries still have failed to implement the global minimum tax for large companies, and it noted that an additional three aren't properly implementing an information exchange law.
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May 23, 2024
G7 Should Agree On Frozen Russian Assets, Yellen Says
U.S. Treasury Secretary Janet Yellen said Thursday that the Group of Seven countries should agree now on a concept of how the capital of frozen and immobilized Russian state assets should be used to support Ukraine's war against Russia.
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May 23, 2024
EU Could Add Sectors To Border Tax, Commissioner Says
The European Union should consider expanding its carbon border tax beyond the initial sectors covered, an EU commissioner has said.
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May 23, 2024
Akerman Brings On Kilpatrick Tax Ace In LA
Akerman LLP is boosting its tax team, bringing in a Kilpatrick Townsend & Stockton LLP corporate tax and energy tax credit expert as a partner in its Los Angeles office.
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May 22, 2024
German Legislature Moves To Update Certain Tax Treaties
The lower house of Germany's legislature has approved a bill to update multiple bilateral tax treaties as part of the country's implementation of the Organization for Economic Cooperation and Development's project against base erosion and profit shifting.
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May 22, 2024
Doctor Must Stay In Jail In Tax Penalty Fight, Gov't Says
A doctor incarcerated for civil contempt for not paying $1.1 million in penalties for failing to report his foreign accounts should remain in jail until he has done more to comply, the U.S. government told a Michigan federal court Wednesday.
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May 22, 2024
Belgium Provides Pillar 2 Reporting Rules
Belgium's finance ministry has issued guidance on what large multinational entities and domestic groups will need to do to comply with the country's coming registration requirement as part of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax.
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May 22, 2024
Guernsey Joins Crown Dependencies Moving Toward Pillar 2
Guernsey will soon take steps to implement the OECD's 15% global minimum tax on large multinational corporations making €750 million ($813 million) annually, in line with fellow U.K. crown dependencies the Isle of Man and Jersey, the island's Finance Ministry said.
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May 22, 2024
Property Transfer For Tax Break Not Dishonest, UK Court Says
Two liquidated London real estate companies failed to convince the United Kingdom Court of Appeal that their former director behaved dishonestly by transferring their holdings to Jersey trusts for less than market value to obtain a tax advantage, according to a judgment released Wednesday.
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May 22, 2024
IRS Again Delays Reporting Rules for Certain BEAT Payments
The Internal Revenue Service is deferring until 2027 the applicability date of requirements for reporting certain intercompany payments that are exempt from the base erosion and anti-abuse tax, the agency announced Wednesday.
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May 22, 2024
IRS Again Delaying Dividend Anti-Abuse Regs
The Internal Revenue Service is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, it announced Wednesday.
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May 22, 2024
UK Gov't Calls Elections For July 4 Despite Poor Polls
Prime Minister Rishi Sunak on Wednesday called an early general election to be held on July 4, advancing the electoral timetable even though his Conservative Party lags decisively behind the opposition Labour Party.
EU Withholding Tax Deal Lacks Ambition, Investors Say
A recently agreed-to streamlining of how cross-border withholding taxes are refunded in the European Union lacks ambition and may not do much to help smaller investors, investor advocates said.
Yellen Opposes Global Redistribution Of Billionaires' Wealth
U.S. Treasury Secretary Janet Yellen repeated Thursday that she opposes a global minimum tax on billionaires and added that she does not support basing a redistribution of the revenue from such a tax on damage from climate change and related financing needs.
Justices' CFPB Alliance May Save SEC Courts, Not Chevron
A four-justice concurrence to the U.S. Supreme Court's decision upholding the Consumer Financial Protection Bureau's unique funding scheme last week carries implications for other cases pending before the court that challenge the so-called administrative state, or the permanent cadre of regulatory agencies and career government enforcers who hold sway over vast swaths of American economic life.
Featured Stories
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Nixing Green Energy Tax Perks Would Be Tough For Trump
Former President Donald Trump has vowed to scrap Democrats' signature 2022 climate law should he get reelected in November, but following through on that campaign promise could prove difficult amid bipartisan support for many of the law's clean energy tax incentives and a potentially divided Congress.
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New Domestic Content Guidance May Boost Energy Credits
The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.
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3 Key Takeaways From Floated Foreign Trust Reporting Rules
Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.
Expert Analysis
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Using A Children's Book Approach In Firm Marketing Content
From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.
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New Crypto Reporting Will Require Rigorous Recordkeeping
The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.
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Exploring An Alternative Model Of Litigation Finance
A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.
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A Vision For Economic Clerkships In The Legal System
As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
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.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
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.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
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.
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This Earth Day, Consider How Your Firm Can Go Greener
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.