International

  • May 24, 2024

    Global Minimum Tax Should Be Tied To Inflation, Report Says

    The €750 million ($814 million) annual revenue threshold for businesses to be considered in scope of the OECD's global corporate minimum tax should be indexed to inflation to protect businesses from being wrongly forced to comply, a think tank report said.

  • May 24, 2024

    UK Calls On Belarus To Undo Suspension Of Tax Agreement

    The U.K. is demanding that Belarus reverse a council resolution that suspends provisions of the double-taxation agreement between the two countries starting June 1, according to a statement released by HM Revenue & Customs.

  • May 24, 2024

    IRS Corrects Notice On Bonus Energy Tax Credit Safe Harbors

    The Internal Revenue Service and U.S. Department of the Treasury issued a correction Friday to a notice providing additional safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts.

  • May 24, 2024

    €14M VAT Fraud Scheme In Belgium, Netherlands Busted

    Seven people were arrested in the Netherlands in connection to a value-added tax fraud scheme involving the Belgian subsidiary of a Dutch company fraudulently claiming a €13.7 million ($14.9 million) refund on trades of goods that never happened, the European Public Prosecutor's Office said Friday.

  • May 24, 2024

    EU Withholding Tax Deal Lacks Ambition, Investors Say

    A recently agreed-to streamlining of how cross-border withholding taxes are refunded in the European Union lacks ambition and may not do much to help smaller investors, investor advocates said.

  • May 24, 2024

    Taxation With Representation: Davis Polk, Wachtell, Latham

    In this week's Taxation With Representation, SouthState Corp. buys Independent Bank Group Inc., CyberArk acquires Venafi, Carlyle clinches its fifth Japanese buyout fund, and AuditBoard Inc. agrees to be bought by Hg Capital.

  • May 24, 2024

    Cyprus, Portugal Aim For National Implementation Of Pillar 2

    Cyprus and Portugal both said Friday that they are moving toward putting the minimum tax known as Pillar Two into their national legislation, which EU law requires them to have done by the end of 2023.

  • May 23, 2024

    Premier League Team Goes Down 2-Nil In VAT Bill Appeal

    Premier League soccer team Nottingham Forest must pay its more than £345,000 ($438,000) value-added tax bill, the U.K.'s Upper Tribunal ruled in a decision published Thursday, dismissing an appeal of a lower court ruling that found HM Revenue & Customs filed its tax assessment on time.

  • May 23, 2024

    Italy Adopts Safe Harbor Global Minimum Tax Rules

    Italy has added a temporary safe harbor provision to its implementation of the Organization for Economic Cooperation and Development's global minimum tax to ease the transition for in-scope companies, the country's finance ministry said.

  • May 23, 2024

    White & Case Adds Former A&O Tax Pro In Luxembourg

    White & Case LLP announced it has added a tax partner to its Luxembourg office from A&O Shearman who specializes in international and Luxembourg corporate tax law.

  • May 23, 2024

    Carbon Pricing Generated Over $100B In 2023, Report Says

    Carbon pricing mechanisms worldwide generated a record $104 billion in revenue in 2023, according to a World Bank report, though it said the 75 instruments currently in force are too few and doing too little.

  • May 23, 2024

    Spain, Greece, Sweden Have Tax Policy Problems, EU Says

    The European Union's executive arm called on Spain, Greece and Sweden on Thursday to change tax laws the bloc finds problematic, while also referring a Spanish tax issue to the European Court of Justice.

  • May 23, 2024

    EU Flags Nations For Shortcomings On Pillar 2, Exchange Law

    The European Commission said Thursday that six European Union countries still have failed to implement the global minimum tax for large companies, and it noted that an additional three aren't properly implementing an information exchange law.

  • May 23, 2024

    Yellen Opposes Global Redistribution Of Billionaires' Wealth

    U.S. Treasury Secretary Janet Yellen repeated Thursday that she opposes a global minimum tax on billionaires and added that she does not support basing a redistribution of the revenue from such a tax on damage from climate change and related financing needs.

  • May 23, 2024

    G7 Should Agree On Frozen Russian Assets, Yellen Says

    U.S. Treasury Secretary Janet Yellen said Thursday that the Group of Seven countries should agree now on a concept of how the capital of frozen and immobilized Russian state assets should be used to support Ukraine's war against Russia.

  • May 23, 2024

    EU Could Add Sectors To Border Tax, Commissioner Says

    The European Union should consider expanding its carbon border tax beyond the initial sectors covered, an EU commissioner has said.

  • May 23, 2024

    Akerman Brings On Kilpatrick Tax Ace In LA

    Akerman LLP is boosting its tax team, bringing in a Kilpatrick Townsend & Stockton LLP corporate tax and energy tax credit expert as a partner in its Los Angeles office.

  • May 22, 2024

    Justices' CFPB Alliance May Save SEC Courts, Not Chevron

    A four-justice concurrence to the U.S. Supreme Court's decision upholding the Consumer Financial Protection Bureau's unique funding scheme last week carries implications for other cases pending before the court that challenge the so-called administrative state, or the permanent cadre of regulatory agencies and career government enforcers who hold sway over vast swaths of American economic life.

  • May 22, 2024

    German Legislature Moves To Update Certain Tax Treaties

    The lower house of Germany's legislature has approved a bill to update multiple bilateral tax treaties as part of the country's implementation of the Organization for Economic Cooperation and Development's project against base erosion and profit shifting.

  • May 22, 2024

    Doctor Must Stay In Jail In Tax Penalty Fight, Gov't Says

    A doctor incarcerated for civil contempt for not paying $1.1 million in penalties for failing to report his foreign accounts should remain in jail until he has done more to comply, the U.S. government told a Michigan federal court Wednesday.

  • May 22, 2024

    Belgium Provides Pillar 2 Reporting Rules

    Belgium's finance ministry has issued guidance on what large multinational entities and domestic groups will need to do to comply with the country's coming registration requirement as part of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax.

  • May 22, 2024

    Guernsey Joins Crown Dependencies Moving Toward Pillar 2

    Guernsey will soon take steps to implement the OECD's 15% global minimum tax on large multinational corporations making €750 million ($813 million) annually, in line with fellow U.K. crown dependencies the Isle of Man and Jersey, the island's Finance Ministry said.

  • May 22, 2024

    Property Transfer For Tax Break Not Dishonest, UK Court Says

    Two liquidated London real estate companies failed to convince the United Kingdom Court of Appeal that their former director behaved dishonestly by transferring their holdings to Jersey trusts for less than market value to obtain a tax advantage, according to a judgment released Wednesday.

  • May 22, 2024

    IRS Again Delays Reporting Rules for Certain BEAT Payments

    The Internal Revenue Service is deferring until 2027 the applicability date of requirements for reporting certain intercompany payments that are exempt from the base erosion and anti-abuse tax, the agency announced Wednesday.

  • May 22, 2024

    IRS Again Delaying Dividend Anti-Abuse Regs

    The Internal Revenue Service is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, it announced Wednesday.

Expert Analysis

  • Breaking Down High Court's New Code Of Conduct

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    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.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    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.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    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.

  • Understanding Discovery Obligations In Era Of Generative AI

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    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.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

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