International
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September 20, 2024
Hong Kong's Tax Revenue Drops For 2nd Straight Year
Hong Kong's tax revenue dipped by HK$14 billion ($1.8 billion) to HK$342 billion in the 2023-24 tax year — the second straight year with a drop — largely because of decreases in stamp duty and profit tax collections, its tax authority said Friday.
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September 20, 2024
Taxation With Representation: Gibson Dunn, Holland & Knight
In this week's Taxation With Representation, CACI International buys Azure Summit Technology, Hotel Engine lands a valuation led by Permira, and Knowles Corp. sells its microphone business to Syntiant Corp.
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September 20, 2024
UK Budget May Seek Gains From Inheritance Tax, Firms Say
The U.K. government may try to squeeze more revenue out of the wealthy via inheritance tax, wealth management firms said Friday following the release of data showing the levy is generating higher returns for HM Treasury.
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September 19, 2024
Pillar 1's Safe Harbor Limits Split Of Taxing Rights, Study Says
The redistribution of corporate taxing rights among countries that agreed to new profit reallocation rules known as Pillar One would be "seriously affected" by a proposed safe harbor, according to report from a think tank funded by the European Union.
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September 19, 2024
Death Doesn't Preclude FBAR Penalties, Judge Says
The death of a U.S. citizen who failed to file reports of foreign bank and financial accounts doesn't stop the U.S. government from enforcing penalties against his estate, a New York federal judge ruled.
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September 19, 2024
Spain Tax Inspections Generated €16.7B In Revenue In 2023
Spain's tax agency said Thursday that it increased the number of control actions it took against large companies and other groups by nearly 14% in 2023 as part of the agency's €16.7 billion ($18.6 billion) in revenue generated from control work last year.
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September 19, 2024
Sweden Aiming For Broad Tax Cuts In 2025 Budget
Swedish taxpayers would see lower tax rates in many areas, such as on their labor and pensions, as part of a proposed 2025 budget that the government sent to the country's legislature for consideration Thursday.
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September 19, 2024
EU, China Fail To End EV Dispute But Talks Continue
Negotiators from the European Union and China failed to resolve a dispute over EU antisubsidy tariffs on imported electric vehicles from China but promised Thursday to intensify efforts to find a mutually agreeable solution.
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September 19, 2024
Nine Countries Sign Treaty For OECD Min. Tax On Payments
Indonesia, Turkey, Congo and six other countries signed a multilateral treaty aimed at implementing a 9% minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group, the OECD said Thursday.
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September 19, 2024
EU Top Court Rules UK's CFC Tax Breaks Not State Aid
The European Court of Justice ruled Thursday that tax breaks the U.K. gave to certain companies under controlled foreign company regulations did not breach European Union state aid law.
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September 19, 2024
Apple Ruling Prompts EU Lawmakers To Call For Tax Justice
Citing the recent European court judgment requiring Apple to pay €13 billion ($14.5 billion) in taxes to Ireland, European Union lawmakers demanded Thursday that the fight against tax evasion and for corporate tax harmonization be stepped up.
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September 19, 2024
EU Wrong To Block Berlusconi's Bank Stake, Top Court Rules
Europe's highest court ruled Thursday that the European Central Bank was wrong to decide that a prior conviction for tax fraud prevented former Italian Prime Minister Silvio Berlusconi from holding a stake in a bank in the country.
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September 18, 2024
Tax Chiefs Eye Crypto Payment Cos., OTC Traders, IRS Says
Tax investigators in the U.S., U.K., Canada, Australia and the Netherlands are preparing guidance on red flags for cryptocurrency payment providers and over-the-counter trading desks following a joint operation this week, a special agent with the Internal Revenue Service said Wednesday.
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September 18, 2024
Tax Court Wrongly Denied Premium Deduction, 5th Circ. Told
A Texas couple asked the Fifth Circuit on Wednesday to reverse a U.S. Tax Court decision denying their bid to deduct more than $1 million in premiums paid to insurance companies they owned, arguing the Tax Court misclassified underlying insurance arrangements.
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September 18, 2024
Most Large Aussie Companies Paying Correct Tax Amounts
The Australian Taxation Office has a high or medium level of assurance that 86% of the country's largest taxpayers paid the correct amount of income taxes in 2024, based on recent reviews.
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September 18, 2024
House GOP Vows Blowback Over OECD's Min. Tax Backstop
House Republicans again warned the OECD that Congress will retaliate against countries that implement a backstop measure to the 15% global minimum tax, saying China will cheat the system and it will cost U.S. taxpayers about $120 billion.
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September 18, 2024
Estonia Implementing 2% Profit Tax To Fund Security
Companies in Estonia will need to pay a 2% tax on their accounting profits starting in 2026 in order to boost investment in the country's defense measures, its Ministry of Finance said.
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September 18, 2024
Country-By-Country Reports In Place In Over 115 Jurisdictions
More than 115 tax jurisdictions require large multinational entities to submit country-by country reports in line with the Organization for Economic Cooperation and Development standards as part of the group's fight against tax base erosion and profit shifting, the OECD reported.
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September 18, 2024
Colombia Should Lower 35% Corporate Tax Rate, OECD Says
Colombia can reignite the since-slowed growth it experienced following the COVID-19 pandemic through a series of tax changes, in particular lowering its 35% corporate income tax as part of an overall rebalancing of the tax burden from corporate to personal income, according to the OECD.
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September 18, 2024
Latham Adds A&O Shearman Energy Group Co-Lead In DC
Latham & Watkins LLP has hired the former co-head of Allen Overy Shearman Sterling's U.S. energy, natural resources and infrastructure group to its team of transactional tax partners based in Washington, D.C., the firm announced Monday.
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September 18, 2024
8th Circ. Considers Chevron's End In 3M's $24M Tax Case
The Eighth Circuit signaled it would consider an argument by 3M that the U.S. Supreme Court's overturning of Chevron deference warranted a reversal in a transfer pricing case in which 3M is challenging the IRS' reallocation of $24 million from a Brazilian affiliate.
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September 18, 2024
Fixing UK Labor Market Could Raise £16B, Report Says
The U.K. labor market has lost almost a million workers since the COVID-19 pandemic, but reversing this could raise more than £16 billion ($21.1 billion) in tax receipts, a research center said Wednesday.
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September 18, 2024
Dutch Government Issues Tax Cuts In First Budget
The new Dutch government issued its first budget since the 2023 elections, including plans to cut taxes on earnings and raise the limit on certain corporate tax deductions.
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September 17, 2024
Tax Court Denies Mineral Co.'s $1.1M Microcaptive Deduction
A mineral rights leasing company set up by an Oklahoma oil businessman can't take a $1.1 million deduction for what was presented as a microcaptive insurance transaction, the U.S. Tax Court ruled, saying the transaction was not a legitimate insurance arrangement.
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September 17, 2024
Cos. Risk Offside Call On Contractor Tax After HMRC Win
The U.K. Supreme Court's decision Monday that Premier League referees count as employees for tax purposes means many companies may have to reassess their arrangements with contractors or risk higher tax costs in the future, tax experts say.
Expert Analysis
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Requiring Leave To File Amicus Briefs Is A Bad Idea
A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.