International
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September 05, 2024
Broad, Low-Rate DST May Placate US, Ex-OECD Chief Tells EU
The European Union might be able to break an impasse with the U.S. in negotiations on taxing the digital economy by proposing a digital services tax with a wide base and a low rate, former OECD tax chief Pascal Saint-Amans told Paolo Gentiloni, the bloc's economics commissioner.
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September 05, 2024
UK Extends Startup Investment Tax Incentives Through 2035
Two U.K. tax incentives that encourage private investment in small companies in order to boost innovation and otherwise stimulate economic growth have been extended for 10 years, HM Treasury said.
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September 05, 2024
Tax Pros Want Aussie PM To Halt Code Of Conduct Changes
Six groups representing Australian tax professionals and accountants called on the country's prime minister to step in to stop an "unfair" bill updating the code of conduct for tax agent services if discussions with the country's Treasury don't produce what they say are needed changes.
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September 04, 2024
IRS' Economic Substance Authority Has Limits, Tax Court Told
The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.
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September 04, 2024
New Zealand Looking To Nearly Triple Its Tourist Levy
New Zealand's government is planning to increase a levy on tourists to NZ$100 ($62) per visit, nearly tripling the current rate, according to a joint statement from the country's conservation and tourism ministries.
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September 04, 2024
Irish Tax Surplus Too Reliant On Few Cos., Watchdog Says
It's dangerous for the Irish government to fund long-term plans with corporate tax windfalls pouring into its coffers for over a decade, as three foreign-owned multinational corporations are providing a growing share, risking volatility in an otherwise healthy economy, a parliamentary watchdog said.
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September 04, 2024
Singapore's Annual Corporate Tax Revenue Climbs 26%
Singapore collected SG$80.3 billion ($61.6 billion) in tax revenue in fiscal year 2023-24, a 17% increase over the prior year, thanks in large part to a 25.6% increase in corporate income tax receipts, pushing that total to SG$29 billion, the country's revenue agency said Wednesday.
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September 04, 2024
Swiss To Impose Second Portion Of Pillar 2 Starting In 2025
Switzerland will implement the income inclusion rule portion of the OECD's Pillar Two standards to fight tax base erosion and profit shifting starting in 2025, its Federal Council said Wednesday, complementing its establishment of the 15% global minimum corporate income tax this year.
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September 03, 2024
11th Circ. Trims $12.6M FBAR Fine In 8th Amendment Split
Some of the $12.6 million in penalties the IRS on imposed a man for willfully failing to report foreign bank accounts were in violation of the Eighth Amendment's bar on excessive fines, the Eleventh Circuit ruled, creating an apparent circuit split.
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September 03, 2024
Bahrain Adopting Global Minimum Tax In 2025
Multinational corporations making more than €750 million ($828 million) annually operating in Bahrain will be subject to the OECD's 15% global minimum corporate income tax starting in 2025, the country's tax agency said.
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September 03, 2024
UN Tax Rule On Payments Best For Many Gov'ts, Group Says
Developing countries should seek to add the United Nations' version of a minimum tax rule on payments to their bilateral tax treaties and to adopt corresponding laws domestically while approaching the OECD's more restrictive multilateral version with caution, an advocacy group said Tuesday.
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September 03, 2024
Ex-Defense Contractor Arrested In $350M Tax Evasion Case
A former defense contractor who, with his wife, is facing a 30-count indictment alleging they were involved in a decades-long scheme to defraud the U.S. government and avoid taxes on more than $350 million in income was arrested Tuesday.
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September 03, 2024
NZ Ratifies Slovakia Tax Agreement, Amends Austria Treaty
New Zealand government ratified a new treaty to avoid double taxation with Slovakia as well as amendments to a previous treaty with Austria, the country's tax agency said.
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September 03, 2024
Non-EU Cos. Need Clarity On Public Tax Reporting, Firms Say
The European Union should clarify how multinational corporations headquartered outside the bloc need to format tax data they report under new public disclosure rules, global accounting firms said.
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September 03, 2024
Higher UK Windfall Tax Will Cut Revenue, Says Industry Group
The U.K. government's plan to raise the energy windfall tax in November may cost HM Treasury around £12 billion ($15.7 billion) in tax revenue, according to an industry group.
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September 03, 2024
Norway Seeks Input On Beneficial Ownership Register Access
Norway's Ministry of Finance is seeking comments on a proposal laying out rules regarding access to the country's beneficial ownership register, the ministry said Tuesday.
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September 03, 2024
IRS Issues More Edits For Foreign Currency Accounting Regs
The Internal Revenue Service issued further corrections Tuesday to proposed rules that would adjust the timing for when companies can use certain accounting methods for gains or losses that arise from foreign currency transactions.
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August 30, 2024
Alvarez & Marsal Appoints Tax Experts As Managing Directors
Alvarez & Marsal Tax LLC appointed tax experts from Anderson and Deloitte as its new managing directors, the firm announced.
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August 30, 2024
Danish Gov't Pledges No Ponzi Analogies At $2.1B Tax Trial
The Danish tax authority won't compare pension funds, investors and attorneys it has accused of defrauding Denmark in a $2.1 billion tax refund scheme to a Ponzi scheme or infamous perpetrator Bernie Madoff, it said Friday in New York federal court.
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August 30, 2024
US Seeks Trade Talks In Dispute Over Canada's Digital Tax
The Office of the U.S. Trade Representative announced Friday that it has requested dispute settlement discussions with Canada regarding the country's recently enacted digital services tax, which the USTR claims discriminates against U.S. companies.
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August 30, 2024
Whistleblower Seeks 2nd Bid At $690M Claim In DC Circ.
A whistleblower denied up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program asked for a D.C. Circuit panel to rehear his case Friday, saying its original opinion included numerous mistakes and misunderstandings.
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August 30, 2024
UK's Labour Gov't Urged To Raise Capital Gains Tax
The Labour government is facing calls to raise the capital gains tax despite financial firms advising investors to sell off their assets or even leave the United Kingdom over the possible tax hike.
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August 30, 2024
IRS Corrects Proposed Rules To Address Pillar 2 Losses
The Internal Revenue Service issued corrections Friday to proposed rules that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.
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August 30, 2024
Taxation With Representation: Kirkland, Paul Weiss, Squire
In this week's Taxation With Representation, Oneok reaches two agreements with energy infrastructure companies worth a total $5.9 billion, McKesson inks a $2.49 billion deal for a cancer center, and First Busey and CrossFirst Bankshares agree to a $917 million merger.
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August 30, 2024
Neb. Justices Affirm Nix Of Berkshire Unit's Tax Deduction Bid
A Nebraska tax deduction for certain dividends doesn't apply to income repatriated under the 2017 federal tax overhaul, the state Supreme Court affirmed Friday in rejecting arguments from a Berkshire Hathaway entity that the state's tax system excluded the foreign earnings from tax.
Expert Analysis
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The Pop Culture Docket: Judge D'Emic On Moby Grape
The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.
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Breaking Down High Court's New Code Of Conduct
The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.
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Legal Profession Gender Parity Requires Equal Parental Leave
To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.
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A Year-End Look At Florida's Capital Investment Tax Credit
Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.
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The Case For Post-Bar Clerk Training Programs At Law Firms
In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.
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AI Can Help Lawyers Overcome The Programming Barrier
Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.
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Preparing Law Students For A New, AI-Assisted Legal World
As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.
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General Counsel Need Data Literacy To Keep Up With AI
With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.
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Navigating Discovery Of Generative AI Information
As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.
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Finding Focus: Strategies For Attorneys With ADHD
Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.
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Attorneys, Law Schools Must Adapt To New Era Of Evidence
Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.
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1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.