International

  • March 21, 2024

    GoDaddy Can't Block Transfer Of $4 Million Set Aside For VAT

    A consortium that sold shares of an internet company to GoDaddy.com can receive a $4 million transfer of escrow funds that GoDaddy claimed were instead needed to pay value-added tax on the share sale, a Dutch court ruled.

  • March 21, 2024

    UN Could Enhance Global Tax Agenda Setting, Officials Say

    The United Nations could play an important role in shaping the agenda for global tax negotiations so it better reflects the priorities and concerns of developing countries, a variety of tax officials said Thursday during a conference.

  • March 21, 2024

    IRS Proposes Exceptions For 3rd-Party Summons Notices

    The IRS proposed rules Thursday that would allow some exceptions to a requirement that the agency notify taxpayers within 45 days before issuing summonses to third parties in tax assessment and collection cases, including for certain time-sensitive examinations.

  • March 21, 2024

    EU Countries Bash Deal On Duty-Free Imports From Ukraine

    Several European Union countries objected to the agreement among EU lawmakers to extend the suspension of the bloc's custom duties and quotas on Ukrainian imports, criticizing a lack of caps on agricultural products.

  • March 21, 2024

    Australia Seeking Input On Global Minimum Tax Bills

    Australia's Treasury is seeking public feedback on three draft bills published Thursday that would implement the Organization for Economic Cooperation and Development's global corporate minimum tax.

  • March 21, 2024

    Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny

    The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.

  • March 21, 2024

    Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group

    Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.

  • March 21, 2024

    €58M VAT Toner Fraud Case Lands Four Convictions In Italy

    Four people were convicted in Italy for their roles in a value-added tax fraud scheme involving printer toner and other office supplies that resulted in €58 million ($63 million) in illicit profits, the European Public Prosecutor's Office said.

  • March 21, 2024

    PwC Still Withholding Names Of Aussie Leak Recipients

    PwC is continuing to refuse to name the six recipients of confidential drafts of Australian tax laws despite repeated requests from the country's government, the firm said in documents published Thursday.

  • March 21, 2024

    HSBC Settles Investors' £240M Claim Over Disney Tax Scheme

    HSBC has settled a £240 million ($304 million) claim brought by more than 100 investors alleging that the bank misled them to finance a Disney film tax relief scheme it developed which turned out to be worthless.

  • March 21, 2024

    UK Insurance Tax Bill Rises To £8.1B Amid Soaring Premiums

    The Insurance Premium Tax raised more than £8.1 billion ($10.3 billion) so far this financial year, according to official figures Thursday, while premiums continue to rise.

  • March 21, 2024

    ECJ Adviser Rejects Taxing Foreign Pension Funds Differently

    Taxing dividends paid to foreign public pension funds while exempting dividends paid to the source country's general retirement savings funds contravenes European Union law, an adviser to the bloc's highest court said Thursday, backing Finnish pension funds' challenge of a Swedish law.

  • March 20, 2024

    IRS Releases Foreign Housing Expense Limits For 2024

    The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.

  • March 20, 2024

    EU Proposes Sending Russian Assets' Revenue To Ukraine

    The European Commission proposed on Wednesday transferring the net income from frozen and immobilized Russian state assets to European Union funds for rebuilding Ukraine and buying arms for that country.

  • March 20, 2024

    How The Supreme Court Could Narrow Chevron

    After hours of oral argument in a closely watched administrative law case, it appeared that some U.S. Supreme Court justices could be open to limiting the opportunities for lower courts to defer to federal agencies' legal interpretations in disputes over rulemaking — and legal experts said there are a number of ways they could do it.

  • March 20, 2024

    OECD Reports More Compliance With Tax Treaty Standards

    The Organization for Economic Cooperation and Development reported Wednesday that members of the group's inclusive framework — countries that have agreed to adopt minimum standards of an international anti-base erosion plan — have increased their compliance with the standard intended to prevent treaty shopping.

  • March 20, 2024

    IRS Withholding Docs On Partnership Audits, Baker Atty Says

    The Internal Revenue Service has not responded to a request for documents pertaining to the agency's scrutiny of large partnerships and should be forced to disclose them, an attorney with Baker McKenzie told a D.C. federal court.

  • March 20, 2024

    EU Floats Alternative To Unanimity As Bloc Eyes Growth

    The European Commission floated an alternative Wednesday to unanimity voting on matters such as tax as it seeks to streamline the way the bloc reaches decisions amid talk of expanding the number of EU countries.

  • March 20, 2024

    IRS Grants Income Exclusion To Those Fleeing 6 Countries

    Individuals who fled conditions in Ukraine, Belarus, Sudan, Haiti, Niger and Iraq after specific dates in 2023 can exclude foreign earned income, and can exclude or deduct housing costs, from gross income that year because of adverse conditions in the countries, the IRS said.

  • March 20, 2024

    Law360 Announces The Members Of Its 2024 Editorial Boards

    Law360 is pleased to announce the formation of its 2024 Editorial Advisory Boards.

  • March 20, 2024

    King & Spalding Adds Ex-PwC Tax Pro As Partner In NY

    An experienced tax attorney has joined King & Spalding LLP in New York after working at PricewaterhouseCoopers LLP for six years.

  • March 20, 2024

    HMRC Makes U-Turn On Helpline Cuts After Backlash

    The U.K. tax authority backtracked Wednesday on plans to close down several helplines for taxpayers from April through September after facing criticism from politicians and industry groups.

  • March 19, 2024

    UN Experts Aim To Finalize Tool For Model Treaty Updates

    The United Nations' tax committee is aiming this week to finalize a tool to facilitate faster adoption of updates to its model tax treaty within bilateral negotiations, although some members remain skeptical about its usefulness, according to discussions Tuesday.

  • March 19, 2024

    GILTI Figures Into CFC Applicability Project, Official Says

    The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday.

  • March 19, 2024

    Pakistan Enlists Nonprofit To Boost Digital Tax Administration

    Pakistan's tax authority said it is partnering with a nonprofit focused on business financing to help the government better understand businesses' needs as it works to improve online tax administration tools.

Expert Analysis

  • 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.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • OFAC Designation Prosecutions Are Constitutionally Suspect

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    Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

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