International

  • June 14, 2024

    G7 Chiefs Agree On Using Frozen Russian Profits For Ukraine

    Leaders from the Group of Seven countries reached a provisional agreement to use windfall profits from frozen and immobilized Russian state assets to back a $50 billion loan to Ukraine, they announced Friday, although details have to be ironed out before the end ot the year, said Italy's prime minister, Giorgia Meloni.

  • June 14, 2024

    Swiss Council OKs Tax Agreements With Angola, Germany

    Switzerland's executive body, the Federal Council, approved a double taxation agreement with Angola and an amendment to an existing agreement with Germany, it announced Friday.

  • June 14, 2024

    Taxation With Representation: Kirkland, Arnold & Porter

    In this week's Taxation with Representation, Noble Corp. PLC buys Diamond Offshore Drilling Inc., Cognizant buys Belcan, AlphaSense raises funding to buy Tegus, and Matador Resources Co. acquires a subsidiary of the EnCap Investments portfolio company Ameredev II Parent.

  • June 14, 2024

    ABA Tax Section Calls For Revision To Stock Buyback Regs

    The U.S. Department of the Treasury and the IRS should narrow a rule in proposed regulations on the stock buyback tax regarding U.S. subsidiaries funding repurchases of their foreign parents' stock, the American Bar Association's Tax Section said in a letter released Friday.

  • June 14, 2024

    Full DC Circ. Won't Hear Foreign Disclosure Penalty Dispute

    The D.C. Circuit declined to reconsider its ruling overturning a major U.S. Tax Court decision that had crimped the administrative collection arm of the Internal Revenue Service, letting stand a panel's restoration of the agency's power to more freely penalize undisclosed foreign corporations.

  • June 14, 2024

    UK Broker Denied Supreme Court Hearing Over Cum Ex Raids

    Judges at a London court refused on Friday to allow a brokerage to challenge at the U.K. Supreme Court findings that a raid on its London office during an investigation into tax fraud in 2022 was legal, finding that the "outcome of any appeal would be no different."

  • June 14, 2024

    EU Transfer Pricing Law To Involve Basic Rights, Prof Says

    A proposed European Union law on transfer pricing would, if adopted, mean the EU's charter of fundamental rights became relevant to transfer pricing disputes, a tax professor said Friday.

  • June 13, 2024

    Canada Should Look Beyond Capital Gains Tax Hike, IMF Says

    Though Canada's proposed capital gains tax increase would be another positive development for a country that has largely fared well in its pandemic rebound, the country should consider more avenues to raise revenue, the International Monetary Fund said.

  • June 13, 2024

    Denmark Considering $302M Entrepreneur Tax Break Package

    Denmark's finance ministry announced a package of more than 2.1 billion kroner ($302 million) in tax breaks and other measures for entrepreneurs that it says will help drive innovation and overall grow the country's attractiveness for startups.

  • June 13, 2024

    EU Eyeing Exchange Rules Linked To Min. Tax, Official Says

    The European Union is looking to introduce rules regarding the exchange of information pertaining to the global minimum corporate tax, a top official in the EU's executive branch said Thursday.

  • June 13, 2024

    Swiss Finance Minister Defends Tax Competition

    Switzerland's finance minister defended tax competition, saying citizens' right to move to lower-tax jurisdictions helps keep public authorities from taxing and spending to excess.

  • June 13, 2024

    EU Scales Back Talks On Proposed Law To Combat Shell Cos.

    European Union countries have broadly agreed to work on a scaled-back legislative proposal to combat shell companies that would give each country more freedom to decide what anti-abuse action to take, an EU official said.

  • June 12, 2024

    Senate Budget Chair Seeks End To Carried Interest Tax Break

    Lawmakers should end the favorable tax treatment of income from carried interest compared with ordinary earned income, Senate Budget Committee Chairman Sheldon Whitehouse said Wednesday.

  • June 12, 2024

    Feds Strike Deal Ending $7M FBAR Penalty Cases

    The U.S. government agreed to settle a pair of foreign bank account reporting cases in which it had sought a total of $7 million from a former insurance broker and his wife's estate, according to a court order filed Wednesday in California federal court.

  • June 12, 2024

    Groups Push Back On Stock Buyback Tax Test's Scope

    The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.

  • June 12, 2024

    Aussie Senate's Final PwC Report Focuses On Integrity Recs

    Australia's Senate released its final report Wednesday regarding PwC's marketing of confidential draft tax laws to clients, pushing for both consulting firms and the government to assure that the firms, particularly the Big Four, act with integrity.

  • June 12, 2024

    Treasury Issued Over $1B In Clean Vehicle Tax Credits

    The clean vehicle tax credit of up to $7,500 has saved buyers more than $1 billion in total upfront costs since January, the U.S. Treasury Department announced Wednesday, saying the figures represent a major milestone in lowering transportation costs since the incentive was updated in 2022.

  • June 12, 2024

    Italy Investigating €13M VAT Fraud Involving Chinese Fabric

    An Italian judge issued a freezing order against four people and a company as investigations continue into a scheme involving the illegal importation of Chinese fabric that caused over €13 million ($14.1 million) in value-added tax losses, the European Public Prosecutor's Office said Wednesday.

  • June 12, 2024

    New Dutch Gov't Agrees On Top Finance Official

    The incoming right-wing Dutch government has agreed to appoint a conservative politician as finance minister and to maintain a separate position for the state secretary for taxation in order to comply with a recent Netherlands Supreme Court tax ruling on compensation to investors, Dutch media reported.

  • June 11, 2024

    US Issues Sanctions For $50M Guyana Gold Tax Evasion

    Two Guyanese businessmen and a Guyanese official were sanctioned by the U.S. Treasury Department on Tuesday after a probe into a corruption scheme that helped the businessmen evade $50 million in gold export taxes that should have been paid to Guyana's government, Treasury said.

  • June 11, 2024

    Latvia Renominates EU Trade Commissioner To Retain Role

    The Latvian government has renominated former Prime Minister Valdis Dombrovskis to retain his European Commission position as the commissioner for trade, the government announced Tuesday.

  • June 11, 2024

    Extension OK'd For Carbon Program Tax Exemption In Norway

    An extension of a program that makes certain carbon emissions tax-exempt for some Norwegian businesses was approved by an official watchdog group Tuesday.

  • June 11, 2024

    Compliance Costs Outweigh Min. Tax Gains, Biz Reps Say

    Multinational businesses are concerned that the burden of complying with the 15% global minimum tax outweighs any potential revenue gains associated with the burgeoning system, tax attorneys and a trade association representative said during a panel Tuesday.

  • June 11, 2024

    House Panel Chair Seeks To End Media Org's Tax Exemption

    The House's top tax writer wants the Internal Revenue Service to revoke the tax-exempt status of a nonprofit Mideast-focused news outlet, telling Commissioner Daniel Werfel that the organization is aiding Hamas.

  • June 11, 2024

    Kostelanetz Partners Talk Benefits Of Atlanta Tax Firm Tie-Up

    Kostelanetz LLP partners Bryan Skarlatos and Todd Welty discuss the firm’s recent combination with Atlanta boutique Welty PC.

Featured Stories

  • Labour Manifesto Targets Wealthy To Fill Funding Gaps

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    Labour set out plans in its election manifesto on Thursday to raise a total of more than £8.5 billion ($10.8 billion) in tax reforms that target wealthy taxpayers, although some analysts questioned whether the measures will add up.

  • Digital Taxes May Take Hold Regardless Of Treaty Signing

    Natalie Olivo

    An internationally agreed-upon freeze on digital levies may continue to thaw even if countries meet their impending deadline to sign a related treaty for new corporate tax rules, in part because the accord faces a hazy path to formal ratification.

  • What Tax Experts Hope To See In Labour's Manifesto

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    Labour's policy manifesto, expected to be unveiled on Thursday, will be studied by tax lawyers for more detail on the fiscal planning being carried out by the clear favorite to win the general election, including a final word on lifetime pension savings.

Expert Analysis

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

  • Trauma-Informed Legal Approaches For Pro Bono Attorneys

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    As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.

  • How Attys Can Avoid Pitfalls When Withdrawing From A Case

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    The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.

  • Using A Children's Book Approach In Firm Marketing Content

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    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

  • New Crypto Reporting Will Require Rigorous Recordkeeping

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    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.