International

  • May 31, 2024

    IRS Guidance Narrows Spinoffs Available For Preapproval

    Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.

  • May 31, 2024

    Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told

    A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.

  • May 31, 2024

    US, Bulgaria Sign Country-By-Country Reporting Agreement

    The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.

  • May 31, 2024

    Latin American Tax Transparency Generates €2.1B In 5 Years

    Tax transparency measures such as exchanges of financial information in Latin American countries have generated nearly €2.1 billion ($2.3 billion) in additional revenue over the past five years, according to an Organization for Economic Cooperation and Development report.

  • May 31, 2024

    Calif. Man Owes 6 Years Of FBAR Penalties, IRS Tells Court

    A Californian has failed to pay foreign bank account reporting penalties he was assessed that were tied to a business he owed in Mexico for six years, the Internal Revenue Service told a federal court.

  • May 31, 2024

    Taxation With Representation: Cravath, Cleary, Fried Frank

    In this week's Taxation With Representation, T-Mobile buys United States Cellular Corp.'s wireless operations, Energy Transfer plans to buy WTG Midstream, ConocoPhillips acquires Marathon Oil, and Goldman Sachs Alternatives raises over $20 billion for its direct lending strategy.

  • May 31, 2024

    Denmark's New VAT System Cuts Errors By 30%, Agency Says

    A new Danish value-added tax reporting system that digitally cross-checks with data for European Union trade has reduced errors by about 30%, Denmark's tax agency said Friday.

  • May 31, 2024

    EU Eyes Permanent End To Vanuatu Visa Waiver

    The European Commission said Friday that it wants to permanently end visa-free access for nationals of Vanuatu to the European Union because the EU says the island nation hasn't addressed risks in its investor citizenship programs.

  • May 30, 2024

    EU Court Rejects Appeal Over Spanish Port Tax Breaks

    The European Union's Court of Justice on Thursday upheld a lower court ruling that corporate tax exemptions Spain extended to seaports were illegal state aid, brushing aside arguments that a more thorough economic analysis was warranted to prove the tax breaks bestowed an unfair advantage.

  • May 30, 2024

    Aussie State's Parliament Urges Taxing Consulting Cos.

    Large companies that provide consulting services to the New South Wales government should be required to pay taxes on their company earnings along with payroll taxes on partnership earnings, according to a report from the Australian state's Parliament.

  • May 30, 2024

    Qatar Signs Double-Tax Agreements With Saudi Arabia, UAE

    Qatar signed two agreements Thursday to prevent double taxation and tax evasion, one with Saudi Arabia and the other with the United Arab Emirates.

  • May 30, 2024

    Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up

    Diplomats agreed this week to finalize a treaty for reallocating some of large companies' tax payments and setting standards to simplify some transfer pricing in lower-income countries by June 30 after having missed a March deadline, according to a statement published Thursday by the OECD.

  • May 30, 2024

    Ex-KPMG Manager Joins Davis+Gilbert As Tax Partner

    A former managing director at KPMG has joined New York law firm Davis+Gilbert LLP as a tax partner in its corporate and transactions practice, Davis+Gilbert announced.

  • May 30, 2024

    Tax Pros Agree With HMRC's Mandatory Agent Reporting Plan

    Two groups representing tax professionals in the U.K. have agreed with a proposed rule requiring practitioners to register with HM Revenue & Customs while also supporting a secondary rule that would require membership with a professional body.

  • May 30, 2024

    Russian Gas Ex-CFO Says $44M FBAR Penalty Is Excessive

    The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks told a Florida federal court that the $44 million in foreign account reporting penalties the government is seeking is illegally high.

  • May 30, 2024

    Panama Papers Leak Led To $283M In Swedish Tax Revenue

    The Swedish Tax Agency said Thursday it has corrected the tax assessments of roughly 100 people and companies connected to the so-called Panama Papers leak, capturing roughly 3 billion Swedish kronor ($283 million) in added tax revenue.

  • May 30, 2024

    Legal Advice On Corp. Setups Protected, ECJ Adviser Says

    A law firm's legal advice, even that concerning the setting up of a corporate investment structure, is within the scope of legal professional privilege guaranteed by European Union law, an adviser to the EU's highest court said Thursday.

  • May 30, 2024

    EU's Top Court Rules Spanish Regional Energy Taxes Illegal

    European Union energy tax law forbids Spanish regions to set their own rates for excise duty on energy, the EU's top court said Thursday, finding that possible exemptions did not apply in the Spanish case.

  • May 30, 2024

    Freeze On UK Tax Thresholds Set To Expire in 2028, Hunt Says

    Chancellor Jeremy Hunt said on Thursday that the freeze on income tax thresholds will continue until 2028, despite promises by the Conservative government to reduce the overall taxation burden in the future.

  • May 30, 2024

    Italian Rules On Internet Companies Unlawful, ECJ Finds

    Amazon, Google, Airbnb and other internet companies have won their fight against a law requiring them to provide Italian authorities with information about their operations as the European Union's highest court ruled Thursday that the obligation breaches of the bloc's rules.

  • May 29, 2024

    Irish Court Denies $19.2M Tax Payment To Australia

    The Australian Taxation Office lost a bid to have a now-liquidated Australian investment company repay a AU$29 million ($19.2 million) tax debt after an Irish court determined the payment should instead go to a lender.

  • May 29, 2024

    Colombian Court Affirms Fossil Fuel Tax Break Must Stay

    The Constitutional Court of Colombia affirmed its decision to strike down a law denying fossil fuel companies the ability to offset corporate income tax liabilities with deductions for royalty payments despite a severe impact to public finances, the country's president said.

  • May 29, 2024

    Baker McKenzie Grows Tax Practice With Ex-KPMG Adviser

    Baker McKenzie announced the hiring of an experienced Chicago-based tax adviser as a principal who most recently spent sixteen and a half years at Big Four accounting firm KPMG.

  • May 29, 2024

    Belgium Opens Pillar 2 Mandatory Reporting Form

    Belgium's finance ministry opened Wednesday its mandatory notification system for entities in scope of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax known as Pillar Two, starting a 45-day clock for such companies to register.

  • May 29, 2024

    Next UK Gov't Should Invest In Tax System, Pros Say

    Improving the administration of the U.K. tax system should be a focus of the country's next government if it hopes to improve economic growth, a group representing tax professionals said, laying out issues that need to be addressed.

Expert Analysis

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • 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

    Excerpt from Practical Guidance
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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.

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