International

  • June 20, 2024

    UK Tax Pros Largely Support 2027 Carbon Border Tax Plan

    Two groups representing tax professionals welcomed the U.K. government's plan to introduce a carbon border tax on certain carbon-intensive imports by 2027, but specifics regarding both default embedded emissions values and carveouts for smaller businesses must be ironed out, they said.

  • June 20, 2024

    Norway's $95M Yearly Dividend Tax Losses Spur Joint Audit

    Norway's tax agency announced a joint audit with other Nordic tax agencies, saying it loses an estimated 1 billion kroner ($95 million) a year in withholding taxes that should be paid by foreign shareholders on dividends but aren't due to aggressive tax planning.

  • June 20, 2024

    Canada Lawmakers OK Digital Tax, Advance Min. Tax

    Canada's Senate passed a 3% digital services tax that would target the revenue of large technology companies, following through on a plan that has drawn criticism from the U.S. and groups representing American tech giants.

  • June 20, 2024

    UK Tax Gap Continues Downward Trend, HMRC Says

    The U.K. has continued to shrink its estimated tax gap, reaching a new low of 4.8% in the 2022-2023 tax year, following a trend of decreases over the past almost two decades, HM Revenue & Customs said Thursday.

  • June 20, 2024

    G20 Should Not Give Up On Pillar 1, Gentiloni Says

    The Group of 20 rich and developing countries should not give up on the Pillar One agreement to reallocate corporate taxing rights globally, European Union tax commissioner Paolo Gentiloni said Thursday, pointing to a G20 summit in November as crucial.

  • June 20, 2024

    EU Adopts Sanctions On Russian LNG, Oil Tanker Fleet

    The European Union agreed in principle Thursday on the 14th economic sanctions package against Russia since its war against Ukraine began, targeting liquefied natural gas, dual-use goods and technologies, and a fleet of oil tankers from non-EU countries.

  • June 20, 2024

    Repatriation Tax Doesn't Violate Constitution, Justices Rule

    The U.S. Supreme Court upheld the 2017 federal tax overhaul's mandatory repatriation levy on Thursday, finding the measure applies to the earnings of foreign corporations with U.S. shareholders and therefore does not raise constitutional questions about taxing unrealized income. 

  • June 20, 2024

    German Casino Tax Regime Is Illegal State Aid, EU Says

    Germany's special tax system for public casino operators violates the European Union's law on state aid law, the bloc's executive branch and treaty regulator said on Thursday.

  • June 19, 2024

    EU Commission Tells France, Italy To Lower Budget Deficits

    The European Commission told France, Italy and six other European Union countries to rein in their big budget deficits on Wednesday, although their governments can decide themselves on the details of spending cuts and tax hikes.

  • June 19, 2024

    Problems With VAT Law Still Not Resolved, Estonia Says

    Estonia said Wednesday that it continues to have concerns about a proposed change to the European Union's value added tax law, which the small northeastern European country said would hurt small businesses.

  • June 18, 2024

    IRS Guidance Doesn't Perceive Spinoff Abuse, Official Says

    Recent IRS guidance limiting the corporate spinoffs that revenue officials will approve as tax-free ahead of time was designed to reflect the drafters' current views, rather than suggest perceived abuse of these transactions, a U.S. Treasury Department official said Tuesday.

  • June 18, 2024

    AbbVie Says IRS Can't Treat $1.6B Break Fee As Capital Loss

    The Internal Revenue Service cannot reclassify as a capital loss a $1.6 billion payment AbbVie made to an Irish biotechnology company after their failed merger and thereby raise the pharmaceutical giant's tax bill by $572 million, the company's attorneys told the U.S. Tax Court.

  • June 18, 2024

    Lithuania Legislature Approves Bank Windfall Tax Extension

    The Lithuanian legislature voted to extend a temporary "solidarity tax" on bank profits through 2025, expecting to generate between €50 million ($53.7 million) and €70 million, it said Tuesday.

  • June 18, 2024

    Hungary Aims To Fight Evasion, Foster Certainty As EU Chair

    Hungary, the incoming chair of the European Union council of member states, said Tuesday that it will prioritize fighting tax evasion and ensuring legal certainty for taxpayers during its time in the role.

  • June 17, 2024

    $2.1B Danish Tax Fraud Defendant Pushes For Separate Trials

    An attorney facing trial alongside his clients on allegations of filing $2.1 billion in fraudulent tax refund claims in Denmark urged a New York federal court to hear his case separately, saying disparate legal arguments could confuse a jury if only one trial is held.

  • June 17, 2024

    OECD Tax Plan Is Developing Nations' Best Choice, Prof Says

    Developing countries could gain more revenue from the OECD's multilateral plan to tax the digital economy than the U.N. Tax Committee's bilateral alternative because they have small treaty networks, many customers and few large companies, an academic argued Monday during an Oxford University panel.

  • June 17, 2024

    Saudi Arabia Should Boost Non-Oil Tax Revenue, IMF Says

    Saudi Arabia has had an "unprecedented economic transformation" in recent years, but maintaining such growth will require further tax efforts, particularly when it comes to non-oil revenue generation, the International Monetary Fund said.

  • June 17, 2024

    OECD Clarifies Rules For Global Minimum Tax

    The OECD-led international negotiating body working on fundamental changes to corporate tax law clarified rules under the global minimum tax on deferred tax and securitization, the organization said Monday.

  • June 17, 2024

    EU Approves Italian Fee Cut For Boats Using Cleaner Energy

    The European Commission approved an Italian plan Monday which, by waiving a fee, incentivizes boats to use a cleaner way of obtaining electricity.

  • June 14, 2024

    US Urges 5th Circ. To Back $2M Tax Bill For Tire Imports

    The Fifth Circuit should overturn a lower court's ruling that a Houston truck company was not an importer responsible for nearly $2 million in excise taxes on tires it bought from a Chinese manufacturer, the U.S. told the Fifth Circuit on Friday.

  • June 14, 2024

    Eaton Says Court Improperly Required Int'l Employee Evals

    An Ohio federal court should reconsider its decision that multinational power management company Eaton must disclose the personnel records of its foreign employees that were requested by the Internal Revenue Service in a transfer pricing investigation, the company told the court.

  • June 14, 2024

    Mining Co. Entity Can't Deduct Loan Interest, UK Court Says

    A U.S. mining company's entity in the U.K. that was created to save taxes through the acquisition of a Texas-based firm cannot overturn the Upper Tribunal's decision that its U.K tax deductions weren't deserved, according to a Court of Appeal judgment.

  • June 14, 2024

    G7 Chiefs Agree On Using Frozen Russian Profits For Ukraine

    Leaders from the Group of Seven countries reached a provisional agreement to use windfall profits from frozen and immobilized Russian state assets to back a $50 billion loan to Ukraine, they announced Friday, although details have to be ironed out before the end ot the year, said Italy's prime minister, Giorgia Meloni.

  • June 14, 2024

    Swiss Council OKs Tax Agreements With Angola, Germany

    Switzerland's executive body, the Federal Council, approved a double taxation agreement with Angola and an amendment to an existing agreement with Germany, it announced Friday.

  • June 14, 2024

    Taxation With Representation: Kirkland, Arnold & Porter

    In this week's Taxation with Representation, Noble Corp. PLC buys Diamond Offshore Drilling Inc., Cognizant buys Belcan, AlphaSense raises funding to buy Tegus, and Matador Resources Co. acquires a subsidiary of the EnCap Investments portfolio company Ameredev II Parent.

Expert Analysis

  • New Crypto Reporting Will Require Rigorous Recordkeeping

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    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

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    Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

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