International

  • May 17, 2024

    Taxation With Representation: Wachtell Lipton, Freshfields

    In this week's Taxation with Representation, Nippon Life acquires Corebridge Financial, Crescent Energy buys SilverBow Resources and Uber purchases Foodpanda.

  • May 16, 2024

    Pillar 1 Faces Hard June Deadline, Ex-Treasury Official Says

    An international agreement to reallocate certain corporate profits, known as Pillar One, will likely stall if countries miss their deadline to sign a multilateral treaty by the end of June, a former U.S. Treasury official said Thursday.

  • May 16, 2024

    Australian Lawmakers OK Tougher Corporate Promoter Rules

    Australian lawmakers agreed Thursday to raise maximum penalties on corporations that promote tax avoidance schemes and to introduce a cap on deductions under its petroleum resource rent tax despite concerns from some members, according to documents published by Parliament.

  • May 16, 2024

    P&G Exec Says FDII Uncertainty May Sway Cos.' IP Decisions

    The 2017 tax overhaul's measure for foreign-derived intangible income, a regime that gives tax breaks for domestically held intellectual property, faces uncertainty that could be one factor in keeping some companies from repatriating IP, a tax executive for Procter & Gamble said Thursday.

  • May 16, 2024

    Eaton Must Give Up Personnel Docs In Transfer Pricing Probe

    Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.

  • May 16, 2024

    African Tax Admins Promote Use Of Voluntary Disclosures

    Voluntary disclosure programs have been very effective when countries launch them in anticipation of complying with an international standard on automatic exchanges of financial account information, the African Tax Administration Forum said Thursday in guidance on the programs.

  • May 16, 2024

    Kenya Considering Global Minimum Tax, DST Replacement

    Kenya is considering legislation that would implement the Organization for Economic Cooperation and Development's corporate global minimum tax as well as repeal and replace the country's digital services tax.

  • May 16, 2024

    Germany's 2024 Tax Revenue Estimate Drops By €14B

    Germany's 2024 tax revenue estimate decreased by roughly €14 billion ($15.2 billion) to €950.3 billion from the estimate made last fall, which its finance ministry said Thursday was due to slower-than-expected economic recovery.

  • May 16, 2024

    Suspected Ringleader Of €2M Cosmetics VAT Fraud Arrested

    The suspected ringleader of a value-added tax fraud scheme at a cosmetics company that caused more than €2 million ($2.2 million) in estimated losses has been arrested by Italian police, the European Public Prosecutor's Office said Thursday.

  • May 16, 2024

    EU Tax On Excess Corp Profits Could Yield €107B, Study Says

    A European Union tax on excessive corporate profits could yield about €107 billion ($116 billion) to partly finance the common EU budget or other urgent investments, leftists in the European Parliament said Thursday.

  • May 16, 2024

    Treasury Provides Extra Relief For Bonus Energy Tax Credits

    The U.S. Treasury Department provided additional safe harbors Thursday that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts in response to the Biden administration's new trade restrictions on solar products from China.

  • May 16, 2024

    Lithuania PM Wants Frozen Russian Assets To Help Ukraine

    Lithuania's prime minister said Thursday that Russia's frozen assets should be used to help Ukraine fight off aggression from its larger neighbor, saying that a recent European decision to use profits from frozen assets should be only a first step.

  • May 15, 2024

    Russian Gas Ex-CFO Can't Nix $44M FBAR Suit, Judge Rules

    The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks can't escape the government's civil suit seeking nearly $44 million in reporting penalties, a Florida federal judge ruled Wednesday.

  • May 15, 2024

    EU Court Upholds Ruling Against Spanish Ship Tax Scheme

    The European Union's General Court upheld Wednesday a European Commission ruling that a Spanish tax scheme for ships constructed in the nation's domestic shipyards was incompatible with the EU's internal market.

  • May 15, 2024

    Schulte Roth Adds Ex-Kleinberg Kaplan Partner To Tax Group

    Schulte Roth & Zabel LLP added a former Kleinberg Kaplan Wolff & Cohen PC partner with a focus on private investment funds to its tax group in New York.

  • May 15, 2024

    3 Key Takeaways From Floated Foreign Trust Reporting Rules

    Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.

  • May 15, 2024

    South African Tax Official Says Data Swaps Too Limited

    South Africa's requests to exchange information on taxpayers with authorities around the world are often denied for criminal investigations of tax crimes, while automatic exchanges sometimes lack the full identifying information of taxpayers, the commissioner of the country's tax agency said Wednesday.

  • May 15, 2024

    Taxpayers Let Down By HMRC Digital Service, Says Watchdog

    HM Revenue and Customs has let down taxpayers by failing to deliver better online services, according to a report published on Wednesday by the public spending watchdog.

  • May 15, 2024

    Swiss Seek Feedback On Crypto Information Exchange

    Switzerland's executive body, the Federal Council, is seeking feedback from the public on its plan to adopt two Organization for Economic Cooperation and Development standards that will update the country's automatic exchanges of information to account for crypto-assets, it said Wednesday.

  • May 15, 2024

    11 Arrested In €25M Italian VAT Fraud Case

    Italian police arrested 11 suspects in a value-added tax fraud ring involving electronic products that resulted in losses of over €25 million ($27.2 million), the European Public Prosecutor's Office said Wednesday.

  • May 15, 2024

    Gentiloni Warns EU States Not To Be Too Harsh With Budgets

    European Union tax commissioner Paolo Gentiloni warned EU countries Wednesday not to be too aggressive with budget cuts, even as some may have to take a more restrictive fiscal stance this year and next than had been planned. 

  • May 15, 2024

    German Finance Minister Wants Lower Tax Burden

    Germany's finance minister said he would like to see the tax burden lowered as part of a broader push to make life less burdensome for industry as the country tries to stimulate economic growth.

  • May 15, 2024

    EU Finance Ministers Plan Road To Tax Revamp

    European Union finance ministers agreed on a work program to implement about 40 measures to improve business financing, including a targeted makeover of tax systems in member countries covering corporate taxes, capital gains and tax breaks for interest payments.

  • May 14, 2024

    A Fifth Of Big Cos. Use Tax Transparency Standard, Org. Says

    About a fifth of the largest 1,000 public companies worldwide have voluntarily used a public country-by-country reporting standard created by an international independent standards organization, the nonprofit said Tuesday.

  • May 14, 2024

    Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight

    The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.

Expert Analysis

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    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.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    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.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    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.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    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.

  • 7 Common Myths About Lateral Partner Moves

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    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.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    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.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    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.

  • A Post-Mortem Analysis Of Stroock's Demise

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    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.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    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.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    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.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

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