International

  • December 05, 2024

    11th Circ. Won't Rethink $100M Credit For John Hancock

    The Eleventh Circuit won't reconsider its decision to let John Hancock Life Insurance Co. keep $100 million in foreign tax credits, leaving in place its October ruling against a Florida law firm retirement plan's trustees.

  • December 05, 2024

    OECD Suggests Tax Shifts To Address Greece's Debt

    Greece has a lot of work to do to reduce its nearly 164% public-debt-to-gross domestic product ratio, and one avenue to generate the kind of budget surplus needed is through a suite of tax changes, the Organization for Economic Cooperation and Development said Thursday.

  • December 05, 2024

    OECD Removes Application Deadline For Int'l Pricing Program

    The Organization for Economic Cooperation and Development said Thursday it has removed biannual deadlines for large multinational entities to apply for the International Compliance Assurance Program, a multilateral effort to resolve transfer pricing issues.

  • December 05, 2024

    Australia Mulling More Country-By-Country Reporting Advice

    While the Australian Taxation Office is already working on guidance for the country's newly adopted public country-by-country reporting rules, it is looking for input on what other areas of the provision businesses may need assistance in interpreting.

  • December 05, 2024

    Authorities Say €38M Greece VAT Fraud Tied To Larger Ring

    Authorities in Greece carried out searches in Athens as part of an investigation into a scheme estimated to have caused €38 million ($40 million) in value-added tax losses, which the European Public Prosecutor's Office said Thursday had connections to a larger €2.2 billion scheme.

  • December 05, 2024

    Australia To Limit Access To Beneficial Ownership Registry

    Australia's government intends to limit public access to a registry of beneficial owners for unlisted entities so that only law enforcement, regulators, journalists and academics can request files initially based on its solicitor's privacy recommendations, the Treasury said Wednesday.

  • December 05, 2024

    Watchdog Urges Ireland To Stash More Of €84B Tax Surplus

    The Irish government should put aside more than the €31 billion ($32.7 billion) it has planned to reserve of the €84 billion tax surplus it expects to have between 2026 and 2030, a budget watchdog said Thursday, citing concerns about U.S. policy changes.

  • December 05, 2024

    HMRC Wins Freezing Order Over Alleged £171M Tax Fraud

    A court imposed a freezing order against three British businesses on Thursday after the U.K. tax authority accused them of orchestrating a £171 million ($218 million) National Insurance fraud.

  • December 04, 2024

    Retired Professor Says He Didn't Waive Rights In FBAR Fight

    An 86-year-old former professor told a California federal court that he raised his Eighth Amendment rights against excessive fines when defending himself against a $545,000 penalty for failing to report foreign bank accounts, disputing arguments by the U.S. government that he had waived those rights.

  • December 04, 2024

    Estonia Plans To Implement Mandatory E-Invoicing By 2027

    Estonia's Ministry of Finance announced Wednesday plans to require businesses to file all invoices electronically in order to enhance the country's collection of value-added taxes while limiting compliance burdens.

  • December 04, 2024

    Australia Floats Thin Capitalization Debt-Test Guidance

    The Australian Taxation Office is seeking public comments on draft guidance related to its third-party debt test, one of three new tests created as part of the country's updated thin capitalization rules.

  • December 04, 2024

    Reed Smith Adds State Tax Partner To San Francisco Office

    Reed Smith LLP added a partner to its national state tax practice who will work out of its San Francisco office, according to the firm.

  • December 04, 2024

    Ringleader Of €6M VAT Fraud Scheme Gets 4-Year Sentence

    A German court issued a four-year prison sentence for a ringleader of a €6 million ($6.3 million) value-added tax fraud scheme involving wireless earbuds, as well as ordering that he pay €960,000, the European Public Prosecutor's Office said Wednesday.

  • December 03, 2024

    Texas Judge Blocks 'Quasi-Orwellian' Anti-Laundering Law

    A Texas federal judge on Tuesday halted the Biden administration's roll-out of new reporting requirements aimed at unmasking anonymous shell companies, granting a nationwide preliminary injunction sought by business interests challenging their constitutionality.

  • December 03, 2024

    Fried Frank Adds Goodwin Procter Tax Pro As Partner In NY

    Fried Frank Harris Shriver & Jacobson LLP announced Tuesday that a Goodwin Procter LLP tax and business law partner has joined the firm and will serve as a partner in Fried Frank's tax department in New York.

  • December 03, 2024

    Exelon Asks For Corp. AMT To Account For Repairs Deduction

    Power companies should be allowed to account for an industry-specific tax deduction on repair costs to determine whether they're subject to the corporate alternative minimum tax, utility giant Exelon said in a comment letter to the U.S. Treasury Department released Tuesday.

  • December 03, 2024

    Australia Expects Royalties, Reporting Guidance In Early 2025

    The Australian Taxation Office said it expects to release draft guidance in February related to a ruling on when payment agreements for software are considered royalties, followed by guidance for exemptions from its new country-by-country reporting laws in March.

  • December 03, 2024

    Comment Deadline Extended For Corp. Alternative Min. Tax

    Treasury and the Internal Revenue Service said Tuesday that they will accept comments on proposed rules for the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more until Jan. 16, a roughly one-month extension from the previous deadline.

  • December 02, 2024

    Russia Looks To 4 FSIA Cases In Bid To Stay $5B Award Suit

    Russia urged a D.C. federal judge to pause a case against it by a Yukos Oil Co. unit seeking to enforce $5 billion in arbitral awards, saying Monday that four parallel Foreign Sovereign Immunities Act cases are pending before the Supreme Court and the D.C. Circuit that could affect the suit.

  • December 02, 2024

    Texas Truck Co. Owes Chinese Tire Import Tax, 5th Circ. Says

    A Houston truck company that sold tires made by a Chinese manufacturer is on the hook for excise taxes as the beneficial owner of the tires, the Fifth Circuit decided in an opinion Monday that reversed a ruling freeing the company from its nearly $2 million tax bill.

  • December 02, 2024

    'Harry Potter' Actor Must Pay £1.8M Tax Bill, Tribunal Says

    Actor Rupert Grint, who portrayed Ron Weasley in the Harry Potter film series, faces a £1.8 million ($2.3 million) tax bill after the U.K.'s First-tier Tribunal ruled that tax avoidance was a primary purpose of an entity created to manage his career.

  • December 02, 2024

    IRS Floats Pooling, Annual Accounting In Offshore Profit Regs

    U.S. multinational companies will be required to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits under proposed rules floated by the U.S. Treasury Department and Internal Revenue Service.

  • December 02, 2024

    A&O Shearman Tax Pro Jumps To Hogan Lovells In DC

    Hogan Lovells said Monday that it has brought on a former Allen Overy Shearman Sterling tax partner who specializes in spinoffs, cross-border deals and other corporate transactions.

  • December 02, 2024

    IRS Finalizes Partnership Liability Regs After 11 Years

    The Internal Revenue Service unveiled final regulations governing the allocation of partnership liabilities 11 years after releasing the proposed rules, saying no subsequent legislative and regulatory changes had taken place to compel the agency to otherwise renew the rulemaking process.

  • December 02, 2024

    Australia Passes Public Country-By-Country Reporting

    Multinational businesses with large operations in Australia are required to publicly disclose information about their operations in tax havens as designated by the government under a country-by-country reporting law that lawmakers adopted following a two-year saga over concerns about the data's confidentiality.

Featured Stories

  • Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2

    Natalie Olivo

    The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.

  • The Tax Angle: TCJA Debate, S Corp. Compliance

    Stephen K. Cooper

    From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • Trump, GOP Victories May Imperil OECD Global Tax Plan

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    President-elect Donald Trump's and Republicans' victories in the U.S. elections this month call into question whether the OECD's two-pillar global tax plan can be effectively implemented and whether the plan's minimum tax backstop rule can be applied amid threats of retaliatory tax measures by the U.S.

Expert Analysis

  • Litigation Inspiration: Reframing Document Review

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    For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.

  • 3 Ways To Train Junior Lawyers In 30 Minutes Or Less

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    Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.

  • The Bar Needs More Clarity On The Discovery Objection Rule

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    Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.

  • So You Want To Move Your Law Practice To Canada, Eh?

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    Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.

  • Promoting Diversity In The Selection Of ADR Neutrals

    Excerpt from Practical Guidance
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    Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.

  • Striking A Balance Between AI Use And Attorney Well-Being

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    As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.

  • How Judiciary Can Minimize AI Risks In Secondary Sources

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    Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.

  • How Attorneys Can Break Free From Career Enmeshment

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    Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.

  • Lawyers With Disabilities Are Seeking Equity, Not Pity

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    Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.

  • Judicial Committee Best Venue For Litigation Funding Rules

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    The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.

  • The Strategic Advantages Of Appointing A Law Firm CEO

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    The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.

  • How Cos. Can Build A Strong In-House Pro Bono Program

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    During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.

  • Home Canning Makes Me A Better Lawyer

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    Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.