International
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November 19, 2024
Austrian Tax Official Tapped To Head Finance Ministry
The head of the Austrian finance ministry's tax policy and tax law section will take over as the country's temporary finance minister, the ministry announced Tuesday.
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November 19, 2024
Spain Committee Sends Min. Tax To Vote Under EU Pressure
Spain's lower house will vote Thursday on a bill that would follow through on an EU directive to implement the OECD's global corporate minimum tax after it was narrowly approved by a finance committee Tuesday as the country faces pressure from the bloc.
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November 19, 2024
Airbnb Ireland Puts Aside $1B For Tax Investigations
Airbnb has put aside €950 million ($1 billion) in Ireland during talks with the Italian Revenue Authority over a tax audit, according to company accounts reported in Irish media.
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November 19, 2024
Treasury Finalizes Partnership Tax Credit 'Direct Pay' Regs
The U.S. Treasury Department finalized regulations Tuesday to make it easier for tax-exempt entities that co-own development projects to qualify for a direct cash payment of clean energy tax credits by electing out of their partnership tax status.
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November 18, 2024
Tax Court Won't Reverse On Foreign Reporting Penalties
The U.S. Tax Court affirmed Monday its position that the IRS lacks authority to assess certain foreign information reporting penalties, denying the agency's request to reverse a ruling that let a Missouri businessowner off the hook for $120,000.
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November 18, 2024
EU Members Face Choice Over Trump Tax Stance, Group Says
Member states of the European Union will have to pick a side if President-elect Donald Trump's incoming administration abandons global tax reform, the Tax Justice Network said Monday.
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November 18, 2024
EU Court OKs Making Execs Show Cause To Escape Tax Debt
It's acceptable under European Union law to require a business director seeking to rid themselves of their company's tax debt to prove they weren't responsible for failing to notify authorities of their inability to pay, the bloc's highest court ruled.
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November 18, 2024
Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2
The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.
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November 18, 2024
6th Circ. Pauses IRS Summons For Eaton Worker Docs
The Sixth Circuit said Eaton Corp. doesn't have to comply with an IRS demand to produce performance reviews for its foreign employees until the appellate court decides whether to overturn a decision that the agency's transfer pricing investigation of the multinational power management company outweighed worker privacy concerns.
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November 18, 2024
Malta Should Work To Align With OECD Min. Tax, IMF Says
Despite its election to delay enacting portions of the OECD's global minimum tax plan under a European Union directive, Malta should develop a plan for adjusting its corporate income tax regime instead of waiting out the clock to implement it, the International Monetary Fund said Monday.
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November 18, 2024
Allen Matkins Adds Stradley Ronon Tax Co-Chair In NY
Allen Matkins Leck Gamble Mallory & Natsis LLP has continued growing its New York office with the addition of the co-chair of Stradley Ronon Stevens & Young LLP's tax department, the firm said Monday.
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November 18, 2024
Poland Enacts Global Min. Tax After EU Pressure
Poland officially implemented the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development following pressure from the European Union to join the majority of the bloc in doing so.
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November 18, 2024
HMRC's £167M Charges To Reuters Group Deemed Lawful
A London court backed HM Revenue & Customs in a case over more than £167 million ($212 million) in diverted profits tax charges issued to U.K. companies in the Thomson Reuters media group.
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November 15, 2024
The Tax Angle: TCJA Debate, S Corp. Compliance
From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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November 15, 2024
Poor Counsel Led To Unjust Tax Convictions, Justices Told
A North Carolina actuary asked the U.S. Supreme Court to review a Fourth Circuit decision denying his bid to reverse his 2016 tax fraud convictions, saying the ruling was based on bad decisions made by his then-trial counsel.
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November 15, 2024
OECD Dispute Resolution Caseload Drops For First Time
The number of open dispute resolution cases under the OECD's mutual agreement procedure decreased nearly 4% in 2023, the first time the OECD observed an annual drop in such cases, it said Friday.
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November 15, 2024
Taxation With Representation: Cravath, MoFo, Gibson Dunn
In this week's Taxation With Representation, Cardinal Health takes a majority stake in GI Alliance and acquires Advanced Diabetes Supply Group, Just Eat offloads Grubhub to Wonder Group, Rivian Automotive and Volkswagen Group launch a joint venture, and Ovintiv Inc. buys Montney Basin assets from Paramount Resources Ltd.
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November 15, 2024
Authorities Uncover €5M VAT Fraud Involving Chinese Imports
A European Public Prosecutor's Office investigation uncovered a scheme involving the importation of Chinese textiles into the EU through Greece and headed to the French market that caused an estimated €5.2 million ($5.5 million) in lost value-added taxes and custom duties, the office said Friday.
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November 15, 2024
OECD Tax Forum Commits To Transforming Tax Systems
The OECD's Forum on Tax Administration, made up of representatives from more than 50 tax jurisdictions, agreed to a set of initiatives Friday intended to drive a "transformation" in global tax administration focused on reducing tax gaps and compliance burdens while increasing tax certainty.
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November 15, 2024
Ireland Forecast To Gain Budget Surplus From Apple Case
The Irish government's budget surplus is expected to rise to 4.4% of gross domestic product next year, much of that as a result of the European Court of Justice's ruling against U.S. tech giant Apple, according to an economic forecast published Friday.
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November 14, 2024
Widow Owes $613K After Mexican Tax Dodge, US Tells Court
The widow of a Texas man faces $613,000 in penalties that her husband incurred by failing to report his foreign bank accounts, the U.S. told a federal court, arguing that she participated in a Mexican real estate transaction to avoid paying the penalties he owed.
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November 14, 2024
Australia Delays Country-By-Country Reporting Deadlines
Entities that have country-by-country reporting obligations for the period ending Dec. 31, 2023, received an automatic one-month extension to file such documents, pushing the deadline to the end of January, the Australian Taxation Office said.
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November 14, 2024
IRS Asks Court To Toss Woman's Inheritance Tax Penalty Suit
A woman who missed the deadline for reporting that she received a $350,000 inheritance isn't allowed to sue the IRS for acting arbitrarily in charging her a late penalty because other remedies to her complaint are available to her, the agency told a California federal court Thursday.
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November 14, 2024
Australia Bill Seeks To Expand Rules On Reporting Ownership
Australia's government wants to fight tax avoidance by making owners of equity derivatives disclose significant owners to regulators and investors, expanding access to that information and giving securities regulators new powers to issue freezing orders for noncompliance, the Australian Treasury said Thursday.
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November 14, 2024
OECD Sees Carbon Pricing Growth Coming After Crisis
While the 2022 energy crisis drove down effective carbon excise tax rates and stalled out the percentage of greenhouse gas emissions covered by such taxes or emissions trading systems, the OECD said Thursday that it expects an increase in covered emissions over the next five years.
Expert Analysis
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What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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4 PR Pointers When Your Case Is In The News
Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.
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Unpacking The Proposed Production Tax Credit Regulations
Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.
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10 Considerations For Litigating A New York Tax Case
While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.
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Law Firm Strategies For Successfully Navigating 2024 Trends
Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.
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Attorneys' Busiest Times Can Be Business Opportunities
Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.
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How Attorneys Can Be More Efficient This Holiday Season
Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.
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How Clients May Use AI To Monitor Attorneys
Excerpt from Practical Guidance
Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.
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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.