International

  • February 16, 2024

    Taxation With Representation: Paul Weiss, Kirkland

    In this week's Taxation With Representation, Diamondback buys Endeavor, KKR & Co. acquires a stake in Cotiviti, and Gilead Sciences Inc. purchases CymaBay Therapeutics Inc.

  • February 16, 2024

    New EU VAT Rules' Impact Will Be Seen In 2025, Official Says

    The impact of the European Union's new reporting obligations for payment processors that handle online cross-border transactions will become clearer starting next year, an EU official said Friday.

  • February 16, 2024

    Singapore Reaffirms Plan To Carry Out Minimum Tax Next Year

    Singapore remains on track to implement the Organization for Economic Cooperation and Development's corporate global minimum tax standards starting next year, the country's finance minister said Friday.

  • February 16, 2024

    Irish Parliament Panel Objects To EU's BEFIT Proposal

    A committee of Ireland's Parliament objected to a new draft framework for corporate taxation in the European Union, saying it oversteps the legal boundaries of EU legislation and undercuts the ability of individual countries to engage in tax competition. 

  • February 15, 2024

    Chamber, Others Back 3M In Transfer Pricing Appeal

    The Eighth Circuit should set aside transfer pricing regulations from the U.S. Treasury Department that reallocated $23 million of income from 3M's Brazilian affiliate to the parent company, three trade associations told the court in amicus briefs.

  • February 15, 2024

    US Extends Deal On Existing Digital Taxes With 5 Countries

    Austria, France, Italy, Spain and the U.K. will continue applying their digital services taxes in light of the extended timeline to implement the Pillar One international profit reallocation agreement, the countries said Thursday in a joint statement with the U.S.

  • February 15, 2024

    Fla. Couple Get 57 Mos. For Evading $42M In Plywood Duties

    A Florida couple were sentenced to nearly five years in prison each after confessing to disguising the Chinese origin of millions of dollars' worth of plywood imports to avoid paying $42 million in import tariffs.

  • February 15, 2024

    HMRC Seeks Input On Tax Administration Capabilities

    HM Revenue & Customs is asking for feedback on its tax administration capabilities, particularly its inquiry and assessment powers, penalties and safeguards, it said Thursday.

  • February 15, 2024

    Mexico Granting Tax Credits For Hydrocarbon Activities

    Mexico has created what it calls a stimulus package for businesses conducting hydrocarbon exploration and extraction, granting tax credits for certain costs incurred over four months stretching back to 2023, according to a presidential decree.

  • February 15, 2024

    CPAs Call For Limiting Currency Recomputation Rules

    The IRS should exclude smaller taxpayers from requirements in proposed regulations for companies to recompute foreign currency gains or losses and income or losses into their parent entities' currencies annually, the American Institute of Certified Public Accountants said in a letter.

  • February 15, 2024

    EU Must Be Ready To Loosen Fiscal Policy, Gentiloni Says

    European Union countries should be ready to loosen their fiscal policy to stimulate the economy if growth slows further and inflation keeps falling, Paolo Gentiloni, the EU's tax commissioner, said Thursday.

  • February 15, 2024

    City Lobby Calls For Tax Cuts, Investment Reform In Budget

    The U.K. government should cut taxes on banking, make it easier for firms to list as public companies and create a new investment office to boost competitiveness, according to a leading financial lobby.

  • February 14, 2024

    Biden's OECD Pick Vows To Warren He'll Avoid Crypto Policy

    A former New York congressman who's been nominated to serve as the U.S. ambassador to a global economic development body has said he'll forgo working on crypto-oriented policy if he's confirmed to the job after Sen. Elizabeth Warren, D.-Mass, expressed concern over his work with cryptocurrency exchange Coinbase.

  • February 14, 2024

    Gov't Atty Says IRS Has Authority For Failure-To-File Penalty

    Internal Revenue Code Section 6021(a) gives the IRS broad authority to assess penalties for failing to file a form mandated by Section 6038(b) on which a company reports its foreign corporations, even though that authority isn't spelled out, a government attorney told the D.C. Circuit on Wednesday.

  • February 14, 2024

    OECD Chief Claims No Knowledge Of Aussie PwC Breaches

    The OECD's top official had no knowledge of PwC Australia's breaches of confidentiality when he took equity in its former CEO's consulting firm that he relinquished when the existence of the equity became public knowledge, his spokesperson told Law360.

  • February 14, 2024

    Jury Wipes Away Texaco Heiress' $21M FBAR Penalties

    A Florida federal jury found Wednesday that the U.S. government hadn't proved a Texaco heiress willfully failed to report foreign bank account information on time, eliminating the almost $21 million in penalties assessed against her estate, according to a court filing.

  • February 14, 2024

    Tech Group Backs 3M In 8th Circ. Transfer Pricing Appeal

    A tax group representing multinational tech companies urged the Eighth Circuit to overturn a U.S. Tax Court ruling that found 3M Co. owed taxes stemming from an additional $23 million in income reallocated from its Brazilian affiliate, saying the decision wrongly upheld transfer pricing regulations that were improperly enacted.

  • February 14, 2024

    UK Top Court Rejects Jersey Co.'s £15M VAT Case

    A company based on the island of Jersey had no grounds to seek £15 million ($18.8 million) in damages from HM Treasury after the U.K. ended a value-added tax relief arrangement in what the company said was a violation of EU law, the U.K.'s Supreme Court ruled Wednesday.

  • February 14, 2024

    Cameroon Agrees To Automatic Exchange Of Tax Info

    Cameroon has committed to enacting the Organization for Economic Cooperation and Development's standard for automatic exchange of financial account information in tax matters by September 2026, the OECD said Wednesday.

  • February 14, 2024

    EU To Remove 4 Jurisdictions From Tax Blacklist

    The European Union is scheduled to remove four jurisdictions from its list of noncooperative jurisdictions, people familiar with the matter told Law360 on Wednesday.

  • February 14, 2024

    HMRC Warns Self-Employed Taxpayers Of Scammers

    Fraudsters are likely to target people who fill in self-assessment tax returns with phishing scams promising a tax refund now that the Jan. 31 filing deadline has passed, HM Revenue and Customs warned Wednesday.

  • February 14, 2024

    EU Tax Havens Shine Because Of Pro Biz Policies, Study Says

    European tax havens differ from their Caribbean counterparts because they attract investors via a favorable combination of taxes and business policies rather than by offering zero tax rates and not cooperating with foreign tax authorities, a study has concluded.

  • February 13, 2024

    Think Tank Says US Should Undermine OECD Global Tax Deal

    The U.S. should try to undermine the OECD's global tax deal by pursuing reforms to corporate tax policy that would maximize the country's attractiveness to international investors and by cutting funding to the organization, the libertarian Cato Institute said Tuesday.

  • February 13, 2024

    Group Wants Long Phase-In Of Rules On Currency Gain, Loss

    The Internal Revenue Service should gradually phase in proposed regulations that would let taxpayers recognize foreign currency gains or losses from a business on an annual basis, the National Foreign Trade Council told the agency.

  • February 13, 2024

    Lawmakers Brace For Lobbying Blitz On Expiring Tax Breaks

    Some lawmakers foresee an increase in lobbying activity this year as Congress considers renewing parts of the GOP's 2017 tax law that are approaching expiration, while efforts to address the influence of dark money in politics remain on hold.

Expert Analysis

  • 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.

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

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