International

  • April 22, 2024

    Partnership Can't Claim $22.7M Loss, Tax Court Says

    The U.S. Tax Court on Monday upheld the IRS' decision to deny a $22.7 million loss deduction claimed by a Connecticut partnership, finding that underlying transactions involving a bankrupt Brazilian company's debt obligations amounted to a disguised property sale.

  • April 22, 2024

    Sweden Proposes Tax Breaks Ahead Of Budget Negotiations

    The Swedish Finance Ministry proposed adjusting its so-called expert tax incentive, which businesses use to attract external workers, among a series of tax changes offered up Monday.

  • April 22, 2024

    Trader Behind £1.4B Tax Fraud Thought Trades Were Valid

    A British trader accused of being the mastermind of a fraudulent trading scheme that cost Denmark's tax authority £1.4 billion ($1.7 billion) genuinely believed that the trades worked, his lawyer told a London court on Monday.

  • April 22, 2024

    Finland Discovers €30M In Undeclared Crypto Profits

    Finnish taxpayers made at least €30 million ($32 million) in undeclared cryptocurrency trade profits in 2022, Finland's tax authority said Monday, reminding taxpayers to include such profits in their filings this year.

  • April 22, 2024

    UAE Considering R&D Tax Break, Seeks Feedback

    The United Arab Emirates is seeking public input to help design a possible research and development tax incentive proposal to help drive innovation and growth, its Ministry of Finance said.

  • April 22, 2024

    Austria Eatery Busted 2nd Time On Tax Evasion Suspicion

    A Chinese restaurant in Austria was busted for a second time on suspicion of evading taxes, this time in the amount of €135,000 ($144,000), the country's finance minister announced, declaring that "the Austrian state cannot be an 'all you can eat' buffet for tax fraudsters."

  • April 22, 2024

    EU Probes Tax Breaks To Chinese Solar Panel Companies

    The European Commission has started two investigations into suspected tax breaks and other possibly illegal foreign subsidies to Chinese solar panel companies bidding for public contracts in Romania, notices in the EU's Official Journal showed Monday.

  • April 19, 2024

    KPMG Supports Aussie Pillar 2 Plan, With Reservations

    KPMG supports Australia's plans to implement the OECD's Pillar Two global minimum corporate tax plan in principle, the accounting firm said Friday, but it has some concerns, including with how often the government diverts from the organization's wording.

  • April 19, 2024

    UN Should Eye Unitary Taxes, DSTs For Tax Pact, Report Says

    Governments should use the United Nations tax convention as an opportunity to advance the overhaul of nexus away from transfer pricing and toward formulary apportionment, including digital services taxes, to achieve unitary taxation on corporate profits, scholars at the Brookings Institution said Friday in a report.

  • April 19, 2024

    UK Tax Pros Worried Public Unaware Of Crypto Tax Liabilities

    With the growing interest in crypto-asset trading, a group representing tax professionals in the U.K. said Friday that it is concerned HM Revenue & Customs isn't doing enough to make the public aware of its tax obligations, particularly with the lowered capital gains exemption.

  • April 19, 2024

    IRS Previews New Digital Assets Reporting Form

    The Internal Revenue Service released a draft of a form brokers will have to use for the first time to disclose their digital asset sales to the agency, including instructions for taxpayers whose transactions are subject to the reporting requirements. 

  • April 19, 2024

    DC Circ. Gives Expat's Challenge To GILTI Another Chance

    A D.C. federal court was wrong to dismiss an expatriate attorney's challenge to the global intangible low-taxed income regulations without addressing his argument that he had no other legal avenue, the D.C. Circuit said Friday as it remanded the case to the lower court.

  • April 19, 2024

    Polsinelli Adds Shareholder To Tax Credit Practice In Dallas

    An attorney who spent more than a decade developing a niche practice specializing in tax credit financing has moved her practice to Polsinelli PC's Dallas office after five years at Munsch Hardt Kopf & Harr PC.

  • April 19, 2024

    India Signs Record Amount Of Advance Pricing Agreements

    India's Central Board of Direct Taxes entered into a record 125 advance pricing agreements with Indian taxpayers in fiscal year 2023-24, a 31% increase compared with the previous year, the authority said.

  • April 19, 2024

    Taxation With Representation: Kirkland, Cleary, O'Melveny

    In this week's Taxation With Representation, Resideo Technologies Inc. announced plans to buy Snap One Holdings Corp., APi Group said it bought an elevator maintenance company, Prysmian said it agreed to purchase Encore Wire, and Sayari said it closed on an investment from TPG.

  • April 19, 2024

    Questions Loom Over China's Pillar 2 Participation

    Practical and political problems surrounding the Organization for Economic Cooperation and Development's 15% global minimum corporate tax raise questions about how China and its biggest companies could undermine that regime.

  • April 19, 2024

    EU Official Pushes Automatic Exchange Of Ownership Data

    The automatic exchange of companies' beneficial ownership information would be a powerful tool for tax authorities and should be a future goal for governments, a senior European Union tax official said Friday. 

  • April 18, 2024

    Estonian Tax System's Ease Key To Success, Bank Head Says

    The tax system in Estonia — ranked the top country for international tax competitiveness by the Tax Foundation — is fair and easy to administer, which is key to the country's tax administration successes, the governor of the Bank of Estonia said Thursday.

  • April 18, 2024

    AbbVie Can't Get Deduction For $1.6B Merger Fee, IRS Says

    The IRS defended its denial of AbbVie's claimed deduction for a $1.6 billion payment to a biotechnology company over their failed merger, telling the U.S. Tax Court that the pharmaceutical giant is misconstruing an underlying statute to challenge the agency's decision.

  • April 18, 2024

    IRS Updates Rates For Foreign Insurance Company Equations

    The Internal Revenue Service published updated domestic asset/liability and yields percentages Thursday that foreign life insurance companies as well as foreign property and liability insurance companies need to compute their minimum effectively connected net investment income for tax years starting in 2023.

  • April 18, 2024

    Pawn Shop Owes VAT On Auction Sales, EU Court Says

    A Portuguese pawn shop must pay value-added taxes of €308,000 ($327,000) from sales commissions of auctioned items because the auction is not part of the exempt loan, the Court of Justice of the European Union said Thursday.

  • April 18, 2024

    EU Split Stops Move Toward Corporate Tax Harmonization

    A group of smaller European Union countries stopped a move toward harmonization of national corporate taxes when EU leaders met Thursday to discuss ways to promote investments in European businesses.

  • April 18, 2024

    $32B More In Tax Yielded In Fiscal '23 Closed Audits, IRS Says

    The Internal Revenue Service closed nearly 583,000 tax return audits in fiscal year 2023, resulting in $31.9 billion of recommended additional tax after examination, the agency said Thursday in its annual data book.     

  • April 18, 2024

    Tax Deadline Near For Irish Corporate Warehoused Debt

    Companies in Ireland taking advantage of the country's debt warehousing regime are encouraged to meet with the tax department ahead of a May 1 deadline to arrange agreements to pay off their liabilities, the country's finance minister said.

  • April 18, 2024

    HMRC Opens Consultation On Payroll Tax In Freeports

    The U.K. tax authority is mulling changes to National Insurance, a payroll levy used to fund state pensions and healthcare, for employees working in special economic zones known as freeports.

Expert Analysis

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • 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.

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