International

  • April 19, 2024

    KPMG Supports Aussie Pillar 2 Plan, With Reservations

    KPMG supports Australia's plans to implement the OECD's Pillar Two global minimum corporate tax plan in principle, the accounting firm said Friday, but it has some concerns, including with how often the government diverts from the organization's wording.

  • April 19, 2024

    UN Should Eye Unitary Taxes, DSTs For Tax Pact, Report Says

    Governments should use the United Nations tax convention as an opportunity to advance the overhaul of nexus away from transfer pricing and toward formulary apportionment, including digital services taxes, to achieve unitary taxation on corporate profits, scholars at the Brookings Institution said Friday in a report.

  • April 19, 2024

    UK Tax Pros Worried Public Unaware Of Crypto Tax Liabilities

    With the growing interest in crypto-asset trading, a group representing tax professionals in the U.K. said Friday that it is concerned HM Revenue & Customs isn't doing enough to make the public aware of its tax obligations, particularly with the lowered capital gains exemption.

  • April 19, 2024

    IRS Previews New Digital Assets Reporting Form

    The Internal Revenue Service released a draft of a form brokers will have to use for the first time to disclose their digital asset sales to the agency, including instructions for taxpayers whose transactions are subject to the reporting requirements. 

  • April 19, 2024

    DC Circ. Gives Expat's Challenge To GILTI Another Chance

    A D.C. federal court was wrong to dismiss an expatriate attorney's challenge to the global intangible low-taxed income regulations without addressing his argument that he had no other legal avenue, the D.C. Circuit said Friday as it remanded the case to the lower court.

  • April 19, 2024

    Polsinelli Adds Shareholder To Tax Credit Practice In Dallas

    An attorney who spent more than a decade developing a niche practice specializing in tax credit financing has moved her practice to Polsinelli PC's Dallas office after five years at Munsch Hardt Kopf & Harr PC.

  • April 19, 2024

    India Signs Record Amount Of Advance Pricing Agreements

    India's Central Board of Direct Taxes entered into a record 125 advance pricing agreements with Indian taxpayers in fiscal year 2023-24, a 31% increase compared with the previous year, the authority said.

  • April 19, 2024

    Taxation With Representation: Kirkland, Cleary, O'Melveny

    In this week's Taxation With Representation, Resideo Technologies Inc. announced plans to buy Snap One Holdings Corp., APi Group said it bought an elevator maintenance company, Prysmian said it agreed to purchase Encore Wire, and Sayari said it closed on an investment from TPG.

  • April 19, 2024

    EU Official Pushes Automatic Exchange Of Ownership Data

    The automatic exchange of companies' beneficial ownership information would be a powerful tool for tax authorities and should be a future goal for governments, a senior European Union tax official said Friday. 

  • April 18, 2024

    Estonian Tax System's Ease Key To Success, Bank Head Says

    The tax system in Estonia — ranked the top country for international tax competitiveness by the Tax Foundation — is fair and easy to administer, which is key to the country's tax administration successes, the governor of the Bank of Estonia said Thursday.

  • April 18, 2024

    AbbVie Can't Get Deduction For $1.6B Merger Fee, IRS Says

    The IRS defended its denial of AbbVie's claimed deduction for a $1.6 billion payment to a biotechnology company over their failed merger, telling the U.S. Tax Court that the pharmaceutical giant is misconstruing an underlying statute to challenge the agency's decision.

  • April 18, 2024

    IRS Updates Rates For Foreign Insurance Company Equations

    The Internal Revenue Service published updated domestic asset/liability and yields percentages Thursday that foreign life insurance companies as well as foreign property and liability insurance companies need to compute their minimum effectively connected net investment income for tax years starting in 2023.

  • April 18, 2024

    Pawn Shop Owes VAT On Auction Sales, EU Court Says

    A Portuguese pawn shop must pay value-added taxes of €308,000 ($327,000) from sales commissions of auctioned items because the auction is not part of the exempt loan, the Court of Justice of the European Union said Thursday.

  • April 18, 2024

    $32B More In Tax Yielded In Fiscal '23 Closed Audits, IRS Says

    The Internal Revenue Service closed nearly 583,000 tax return audits in fiscal year 2023, resulting in $31.9 billion of recommended additional tax after examination, the agency said Thursday in its annual data book.     

  • April 18, 2024

    Tax Deadline Near For Irish Corporate Warehoused Debt

    Companies in Ireland taking advantage of the country's debt warehousing regime are encouraged to meet with the tax department ahead of a May 1 deadline to arrange agreements to pay off their liabilities, the country's finance minister said.

  • April 18, 2024

    HMRC Opens Consultation On Payroll Tax In Freeports

    The U.K. tax authority is mulling changes to National Insurance, a payroll levy used to fund state pensions and healthcare, for employees working in special economic zones known as freeports.

  • April 18, 2024

    Transfer Pricing And Dancing: Recalling KPMG's Sean Foley

    Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world's top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG's practice.

  • April 18, 2024

    UN Tax Work Should Be Consensus-Driven, EU Official Says

    The work on international taxation at the United Nations should be driven by consensus, as otherwise, whatever agreement comes out of the process won't be accepted globally, a senior European Union tax official said Thursday.

  • April 17, 2024

    Gov't Officials Urge Global Cooperation On Taxing Wealth

    Global cooperation on taxing the wealthiest individuals and companies is necessary to address climate change and create social justice, government officials from Brazil, France and Nigeria said Wednesday at the International Monetary Fund's spring meeting.

  • April 17, 2024

    Swedish Tax Investigations Add $90M To Crypto Miners' Bills

    Investigations revealed that a number of cryptocurrency mining centers in Sweden misrepresented their business dealings, which led to the Swedish Tax Agency doling out a total of 990 million Swedish krona ($90 million) in increased tax liabilities, the agency said Wednesday.

  • April 17, 2024

    Consensus Key To UN Tax Progress, Developing Nations Say

    Achieving consensus is important to ensure progress on the United Nations framework convention on tax, the top group for developing countries to coordinate on financial policy said in a formal statement.

  • April 17, 2024

    Aussie Tax Office Misses Transfer Pricing Review Goals

    In each of the past two years, the Australian Taxation Office came up short of its goal to review every use of transfer pricing for related party debt made by entities included in two major economic categories, a government audit revealed Wednesday.

  • April 17, 2024

    Johnston Carmichael Adds Ex-Alvarez Tax Pro In Glasgow

    U.K. accounting and business advisory firm Johnston Carmichael has recruited an accountant from Alvarez & Marsal to work as a financial services tax partner in its Glasgow office.

  • April 17, 2024

    Canada Proposes Top-End Tier To Boost Capital Gains Tax

    Canada's government is seeking to introduce a new tier to its capital gains tax regime, increasing the portion of gains on which tax is paid to two-thirds from the current 50% for any capital gains more than CA$250,000 ($182,000).

  • April 17, 2024

    Judge Delays Trial Over $20M Allegedly Hidden From IRS

    A Florida federal judge agreed Wednesday to delay the trial of a Brazilian-American businessman accused of hiding $20 million from the Internal Revenue Service by using Swiss bank accounts, but told the defendant the new deadlines are firm.

Featured Stories

  • 3 Key Takeaways From The IRS' Latest Pricing Pact Snapshot

    Natalie Olivo

    The IRS finalized a record number of advance pricing agreements in 2023, signaling the agency's increased effectiveness at completing accords at a time when its approach to transfer pricing litigation could fuel corporate taxpayers' urgency for seeking APAs. Here, Law360 breaks down three key takeaways from the agency’s latest APA report.

  • 4 Takeaways From Tax Court Nix Of Easement Perpetuity Rule

    Kat Lucero

    The U.S. Tax Court's scrapping of an IRS rule on the perpetuity requirements for conservation easements could draw yet more judicial scrutiny to the agency's rulemaking and shift the focus of easement disputes to how the transactions are valued. Here, Law360 examines four key takeaways from the decision.

  • Denmark's £1.4B Tax Fraud Trial Heads For 'Uncharted Waters'

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    Denmark will open its £1.4 billion ($1.7 billion) dividend fraud case in London on Monday, beginning a yearlong trial that will have wide implications for other disputes arising out of the cum-ex trading scandal that has swept Europe.

Expert Analysis

  • 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.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.

  • Judicial Independence Is Imperative This Election Year

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    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.