International
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November 25, 2024
Aussie Gov't Proposes Green Energy Production Tax Credits
Australia's government has unveiled a sweeping new tax incentive program to accelerate investment in renewable hydrogen and critical minerals in an attempt to meet its commitment to a net-zero energy transformation.
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November 25, 2024
Payments To Exxon Unit Taxable, Australian Panel Says
Exxon Mobil unit Esso is liable for tax on monthly payments it received for processing its Australian business partners' petroleum and on an AU$23.4 million ($15.5 million) lump sum payment, a panel at the Federal Court of Australia said, overturning an earlier judgment at the same court.
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November 25, 2024
Feds Violated Atty-Client Rules, Tax Evasion Defendant Says
A Brazilian-American businessman accused of using Swiss bank accounts to hide $20 million from the Internal Revenue Service asked a Florida federal court to dismiss all the charges against him, saying federal prosecutors improperly gained access to information protected by attorney-client privilege.
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November 25, 2024
IRS Corrects Advanced Manufacturing Production Credit Regs
The Internal Revenue Service issued a correction notice Monday concerning final rules for the advanced manufacturing production credit.
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November 25, 2024
Tax Hikes Will Make It Harder To Hire, UK Industry Chief Says
Businesses will hire fewer workers as a result of raising employers' National Insurance contributions, a payroll levy, that was introduced in the autumn budget, the chief of one of Britain's most influential industry groups said Monday.
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November 22, 2024
Trump Taps Hedge Fund Billionaire Bessent To Head Treasury
President-elect Donald Trump on Friday announced that he's selected Scott Bessent, a billionaire hedge fund manager and the founder of Key Square Group, to serve as secretary of the Treasury in his upcoming administration.
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November 22, 2024
IRS Extends Domestic Content Relief For Energy Credits
Nonprofits, tribal governments, public utilities and other tax-exempt groups eligible for a direct cash payment of their clean energy tax credits can get relief from meeting the domestic content requirements tied to those incentives for 2025 and 2026 under IRS guidance released Friday.
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November 22, 2024
Canada Proposing 2-Month GST Holiday For Groceries, Gifts
Canada's government is sending a proposal to its Parliament that would implement a two-month goods-and-services tax holiday starting in mid-December on goods ranging from certain groceries to Christmas trees.
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November 22, 2024
Isle Of Man Parliament Passes OECD's Global Minimum Tax
The Isle of Man's Parliament approved a bill implementing two portions of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities making at least €750 million ($781 million) annually, starting in 2025.
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November 22, 2024
IRS Ignores Text In $248M Fight, Liberty Global Tells 10th Circ.
The Internal Revenue Service is incorrectly applying the U.S. tax code in denying Liberty Global's claim for $248 million in foreign tax credits tied to its sale of a Japanese affiliate, the telecommunications company told the Tenth Circuit.
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November 22, 2024
Halliburton Omitted Grounds From $35M Refund Suit, US Says
A Texas federal court must dismiss parts of Halliburton's $35 million tax refund lawsuit because the company failed to raise two grounds of relief in its administrative claim for a refund, the U.S. argued.
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November 22, 2024
Taxation With Representation: Stradley Ronon, Davis Polk
In this week's Taxation With Representation, Amcor PLC buys Berry Global Group Inc., AeroVironment buys BlueHalo, Robinhood Markets Inc. acquires TradePMR, and Comcast Corp. spins off a suite of NBCUniversal cable television networks.
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November 22, 2024
2 Convicted In €3.7M EU VAT Fraud Scheme
A German court convicted two people for their roles in a value-added tax fraud scheme involving small electronic goods that caused an estimated €3.7 million ($3.86 million) in lost tax revenue, the European Public Prosecutor's Office said.
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November 22, 2024
Spain Raises Bank Windfall Levy, Enacts Minimum Tax
The Spanish government is set to increase its windfall tax on banks with more than €5 billion ($5.2 billion) in income as well as implement a minimum corporate tax on multinational companies following a vote by lawmakers.
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November 21, 2024
EU Official Says GILTI Changes Could Nullify Pillar 2 Backstop
The U.S. has an opportunity to shield multinationals from the Pillar Two 15% global minimum tax backstop rule in other jurisdictions by revising its tax on global intangible low-taxed income next year, a European Union tax official said Thursday.
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November 21, 2024
Australia Floats Paths For Adopting Crypto Disclosure Rules
The Australian government floated two options Thursday for implementing a global crypto-asset reporting framework: adopt a standardized model or take a "bespoke approach" that would offer more flexibility but may also increase compliance costs.
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November 21, 2024
Breach Of VAT Rules Can Block €385K Refund, ECJ Rules
Bulgarian tax authorities can deny a value-added tax refund of approximately €385,000 ($403,000) to a domestic company that did not have the tax itemized on invoices, the European Court of Justice ruled Thursday.
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November 21, 2024
6 Nations Must Improve Transparency Framework, OECD Says
Six countries that have generally complied with global standards for exchanging financial information for tax purposes could nevertheless improve their mechanisms for accessing data about entity owners, according to reports released Thursday by the Organization for Economic Cooperation and Development.
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November 21, 2024
VAT Stays King Of Consumption Taxes Across OECD
Value-added tax revenue continued to be the largest category of consumption taxes across the Organization for Economic Cooperation and Development in 2022, it said Thursday, generating an average of 20.8% of total revenue in 2022, a 0.1 percentage point increase.
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November 21, 2024
Tax Revenue Ratio Remained Steady In 2023, OECD Says
The average tax-to-gross domestic product ratio across Organization for Economic Cooperation and Development countries remained relatively steady in 2023 compared with the year prior, the OECD said Thursday, even as they deal with challenges such as the increasing cost of living and climate change.
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November 21, 2024
Israel-Hamas War Tax Relief Needed More Notice, TIGTA Says
While the Internal Revenue Service did well to proactively identify taxpayers likely affected by the Israel-Hamas war that it sought to grant tax relief, it failed to directly notify these taxpayers, the Treasury Inspector General for Tax Administration said Thursday.
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November 21, 2024
11th Circ. Asked To Rethink $100M Credit For John Hancock
The Eleventh Circuit should reverse its decision allowing John Hancock Life Insurance Co. to keep $100 million in foreign tax credits that rightfully belong to the company's investors, trustees of a retirement plan said in arguing that the court overlooked a key U.S. Treasury regulation.
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November 21, 2024
Ryanair Threatens To Cut France Flights Over Ticket Tax
Irish budget airline Ryanair warned it would suspend flights to and from 10 regional airports in France if the country goes through with its proposed tax on plane tickets, which would take effect in January.
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November 20, 2024
India's Top Court Allows Tax Credits For Excise Duties Paid
Excise duties that India's mobile telecommunication providers pay when building the infrastructure for their networks — such as transmission towers — can be used as tax credits, the Supreme Court of India ruled Wednesday.
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November 20, 2024
NY Says Changes To Fed. Tax Return Reset Refund Timeline
A couple living in Switzerland for part of each year timely filed their claim for overpaid New York state income taxes dating back to 2011 soon after winning double-taxation relief under the Swiss-U.S. tax treaty in 2018, the state's tax department said.
Expert Analysis
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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.
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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7 Common Myths About Lateral Partner Moves
As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.