International
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September 24, 2024
Halliburton Tardy In Contesting $35M Deduction, US Says
A Halliburton Co. lawsuit claiming a deduction for a $35 million payoff to a foreign country must be dismissed because the company waited too long to start its action, the U.S. told a Texas federal court.
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September 24, 2024
Microsoft Fights Mich. Tax Treatment Of Cost Share Payments
Microsoft urged the Michigan Tax Tribunal to find that cost sharing agreement receipts from affiliates constituted licenses of intellectual property that should be included in its apportionment formula, arguing that the state's tax agency incorrectly followed federal transfer pricing rules in excluding the payments from its tax calculations.
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September 24, 2024
Digital Asset Rules Coming By Year's End, Treasury Atty Says
The U.S. Treasury Department and the Internal Revenue Service intend to release rules "later this year" on additional reporting requirements for brokers of digital assets such as cryptocurrency and nonfungible tokens, a senior Treasury attorney said Tuesday.
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September 24, 2024
Abbott Seeks $24M Refund Over Transfer Pricing Adjustments
Healthcare products giant Abbott Laboratories is owed $24.3 million for overpaid taxes after the IRS incorrectly adjusted its intragroup income and payments this year, the company told the U.S. Tax Court in a petition.
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September 24, 2024
IRS Wary Of Adding Complexity In Min. Tax Regs, Official Says
The IRS opted to use existing tax rules in proposed guidance to address risks that the U.S. corporate alternative minimum tax could count offshore income twice, an agency official said Tuesday, noting a more precise method would increase complexity.
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September 24, 2024
Australia Floats Denying Late, Wrong Tax Interest Deductions
Australia's government opened a consultation Tuesday on a measure that would deny tax deduction claims for interest charged on late payments of tax liabilities as well as for interest charged when incorrect self-assessments result in a shortfall of tax paid.
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September 24, 2024
Treasury To Allow 3 AMT Transition Methods, Official Says
Final rules on the new corporate alternative minimum tax are expected to adopt the proposed regulations' three ways for companies to transition to the regime, and the U.S. Treasury Department is open to other ways as well, a department official said Tuesday.
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September 24, 2024
Exxon Claims It Beat Weak Defense In $1.8B Tax Trial
Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.
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September 24, 2024
Azerbaijan Ratifies OECD Tax Treaty Standards
Azerbaijan ratified the Organization for Economic Cooperation and Developement's multilateral convention on base erosion and profit shifting Tuesday, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said.
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September 24, 2024
HMRC Set To Launch Consultation On VAT E-Invoicing
HM Revenue & Customs will hold a consultation on e-invoicing for value-added tax "soon," the British Treasury confirmed following a speech by the chancellor.
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September 24, 2024
Miller & Chevalier Adds Federal Tax Expert From White & Case
Miller & Chevalier Chtd. announced that it added a former partner at White & Case LLP to its tax controversy and litigation practice.
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September 23, 2024
Clean Energy Safe Harbor Applies To Direct Pay, Official Says
The safe harbor for the bonus clean energy tax credits' domestic content rules applies to all applicable project owners, including tax-exempt entities that are eligible to get a direct cash payment of the credits, a U.S. Treasury Department attorney said Monday.
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September 23, 2024
The Tax Angle: Corporate Inversions, SALT Cap
From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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September 23, 2024
Sysco Allowed $324M Dividend Deduction After Varian Ruling
Sysco Corp. can deduct $324 million in foreign dividends after agreeing with the Internal Revenue Service that a decision in a similar case brought by Varian Medical Systems resolved their dispute, the U.S. Tax Court said in an order.
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September 23, 2024
Disney Asks Justices To Review NY Tax On Foreign Royalties
New York's highest court used the wrong standard for evaluating tax statutes for discrimination when it denied deductions that The Walt Disney Co. sought for royalties received from foreign affiliates, the company argued in a petition to the U.S. Supreme Court that Law360 obtained Monday.
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September 23, 2024
Singapore Man Sentenced To 4 Years In $43M Fraud Scheme
A Singapore man involved in a scheme that made SG$55 million ($43 million) in fictitious sales that resulted in more than SG$7.5 million in fraudulent goods-and-services tax, or GST, refund claims was sentenced to more than four years in prison Monday, the country's revenue authority said.
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September 23, 2024
IRS Finalizing Pricing Pact Guidance, Official Says
The Internal Revenue Service is in the final stages of updating revenue procedures to help multinational corporations pursue advance pricing agreements and resolve tax treaty disputes, and it will release the guidance soon, an agency official said Monday.
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September 23, 2024
Irish Carbon Tax Could Generate €8.8B By 2030, Report Says
Planned rate increases and other factors could see Ireland's carbon tax generate at least €8.8 billion ($9.8 billion) in revenue over the next six years, compared with over €3.3 billion generated from 2019 through 2023, the country's Financial Services Division said.
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September 23, 2024
Squire Patton Tax Ace Joins Winston & Strawn In Dallas
Winston & Strawn LLP announced Monday it has expanded its tax offerings with the addition of an experienced attorney from Squire Patton Boggs LLP in Texas.
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September 23, 2024
HMRC Raises £1B Cracking Down On Tax Fraud
HM Revenue & Customs raised almost £1 billion ($1.3 billion) in its most serious criminal investigations of tax fraud year-on-year in April, according to research published by a law firm Monday.
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September 23, 2024
Belgium Has High Tax Burden, Public Debt, OECD Says
While there are some tax changes Belgium should consider, the country should tackle its high public debt through better spending practices because its tax burden is among the highest in the OECD, the organization said Monday.
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September 23, 2024
Pension Experts Urge Tax Breaks For UK Investment Plan
The government could best encourage investment in the economy from pension schemes by adopting tax incentives, a trade body said.
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September 20, 2024
8th Circ. To Hear Args In 3M's $24M Tax Case Next Month
The Eighth Circuit said Friday that it will hear oral arguments next month in 3M's transfer pricing appeal, in which the multinational conglomerate is challenging the Internal Revenue Service's authority to reallocate to the company $24 million from a Brazilian affiliate.
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September 20, 2024
IRS Special Trial Attorney Joins Hochman Salkin In California
When Hochman Salkin Toscher Perez PC's newest principal, Sebastian Voth, was studying at Emory University School of Law, a former chief counsel for the Internal Revenue Service told students that the IRS was a great place to start their careers. After 15 years as an IRS attorney, Voth found that the agency was also a great place to work, he told Law360 Pulse in an interview Friday.
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September 20, 2024
Australia Seeks Comments On Luxury Car Tax Green Changes
Australia is looking for comments on plans to adjust the country's luxury car tax to update the definition of a fuel-efficient car and to make changes to the way the tax threshold is indexed, the country's Treasury Department said Friday.
Expert Analysis
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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.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.