International

  • December 16, 2024

    Canadian Finance Minister Resigns Amid Trump Tariff Threats

    Canada's deputy prime minister and minister of finance announced Monday that she is resigning from her post, citing conflicting views with Prime Minister Justin Trudeau about how to respond to tariff threats under President-elect Donald Trump's incoming administration.

  • December 16, 2024

    Work Still Needed To Keep VAT In EU Effective, Group Says

    Following the European Union's agreement on a value-added tax reform package, a group of EU VAT experts presented a wide-ranging suite of short- and long-term proposals Monday aimed at making sure the bloc's regime remains effective as the landscape continues to shift.

  • December 16, 2024

    Cos. Urge Judge To Maintain Injunction On Transparency Law

    A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.

  • December 16, 2024

    Wyden Bill Would Nix Tax Perks For Private Placement Plans

    U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.

  • December 16, 2024

    HMRC Chief Defends Record On Fighting Tax Evasion

    The chief executive of HM Revenue & Customs told Parliament on Monday that the British tax authority has reduced the level of tax noncompliance in response to claims it needs a better strategy on tax evasion.

  • December 16, 2024

    Info On Over 1,900 Tax Rulings Swapped In OECD Last Year

    Tax jurisdictions within the Organization for Economic Cooperation and Development spontaneously shared information related to over 1,900 tax rulings involving foreign companies in 2023, the OECD said Monday, highlighting the widespread adoption of its transparency framework aimed at mitigating harmful tax practices.

  • December 16, 2024

    Hong Kong Commits To OECD Crypto Reporting Framework

    Hong Kong plans to take part in the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets starting in 2028, the jurisdiction's Inland Revenue Department said.

  • December 13, 2024

    IRS Aims To Ramp Up Partnership Audits, Official Says

    The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.

  • December 13, 2024

    OECD Seeks Input On Ring-Fencing Mining Income Guidance

    The Organization for Economic Cooperation and Development said Friday that it is looking for feedback on proposed guidance for tax administrations looking to set up ring-fencing measures for mining operations in order to limit investors' ability to offset expenditures and revenues between projects.

  • December 13, 2024

    Swiss Gov't Rejects Retroactive Tax On Gifts Above $56M

    The Swiss federal government formally rejected a wealth tax proposal by the youth wing of the Social Democratic Party of Switzerland on Friday, saying a retroactive 50% tax on gifts and inheritances above 50 million Swiss francs ($56 million) was "politically questionable."

  • December 13, 2024

    Canada Must Reassess Tax Bills For Ex-Blue Jays, Court Says

    Pension contributions made by two former Major League Baseball stars while they played for the Toronto Blue Jays should be counted in their annual income, the Tax Court of Canada ruled in a victory for the former players.

  • December 13, 2024

    CFC Tax Issues Can't Be Solved Via Treaties, Officials Say

    Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.

  • December 13, 2024

    IRS Mulls Turning Off Foreign Currency Rules For CFCs

    The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.

  • December 13, 2024

    Halliburton Consistent On Claims For $35M Refund, Court Told

    Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.

  • December 13, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.

  • December 13, 2024

    Canada 2-Month Sales Tax Holiday Begins Saturday

    A two-month goods-and-services tax holiday in Canada on certain goods such as gifts and restaurant meals will begin Saturday after having passed the Senate and receiving royal ascension.

  • December 13, 2024

    Contractor Loses Bail For Texting Alleged Tax Cheat Allies

    A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.

  • December 13, 2024

    Loper Bright May Influence Tax Less, IRS Chief Counsel Says

    The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.

  • December 12, 2024

    IRS Wants Choice Retained In Dual Loss Rules, Official Says

    The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.

  • December 12, 2024

    IRS Seeks Feedback On Limits In Previous Taxed Profit Rules

    The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.

  • December 12, 2024

    CJEU Upholds €1.8M Tax On Volvo Group In Belgium

    Belgium can impose a "fairness tax" totaling €1.8 million ($1.9 million) on nonresident companies without a permanent office in the country, the Court of Justice of the European Union said Thursday.  

  • December 12, 2024

    2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties

    The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.

  • December 12, 2024

    Swiss To End Credit Offsetting India's Tax Treaty Snub

    The Swiss government will no longer offer a credit to taxpayers designed to offset India's rejection of Swiss claims to benefits offered in other Indian tax treaties because India's top court decided to uphold its government's position, according to a notice.

  • December 12, 2024

    German Fund Managers Charged In €45M Cum-Ex Scheme

    Two fund managers have been charged in Germany for "particularly serious" tax evasion over their alleged role in a €45 million ($47 million) cum-ex dividend tax fraud, prosecutors confirmed Thursday.

  • December 12, 2024

    IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

    Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.

Expert Analysis

  • Lawyers Can Take Action To Honor The Voting Rights Act

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    As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.

  • How To Grow Marketing, Biz Dev Teams In A Tight Market

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    Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.

  • Rock Climbing Makes Me A Better Lawyer

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    Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.

  • Contract Disputes Recap: Preserving Payment Rights

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    Stephanie Magnell and Zachary Jacobson at Seyfarth examine three recent decisions that together illustrate the importance of keeping accurate records and adhering to contractual procedures to avoid inadvertently waiving contractual rights to cost reimbursements or nonroutine payments.

  • Think Like A Lawyer: Dance The Legal Standard Two-Step

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    From rookie brief writers to Chief Justice John Roberts, lawyers should master the legal standard two-step — framing the governing standard at the outset, and clarifying why they meet that standard — which has benefits for both the drafter and reader, says Luke Andrews at Poole Huffman.

  • Lead Like 'Ted Lasso' By Embracing Cognitive Diversity

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    The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.

  • Now More Than Ever, Lawyers Must Exhibit Professionalism

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    As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

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