International
-
April 29, 2024
Canada Opens Second R&D Tax Credit Consultation
With an additional CA$600 million ($439 million) earmarked for its scientific research and experimental development tax incentive program, Canada is looking for more specific feedback on expanding and otherwise adjusting the regime.
-
April 29, 2024
Poland Pushes Back Mandatory E-Filing After Finding Flaws
Polish businesses with sales totaling more than 200 million zloty ($50 million) won't have to use the country's electronic invoice system until 2025, with the full rollout delayed until 2026, due to multiple problems uncovered in the system, the country's tax authority said.
-
April 29, 2024
OECD-UN Initiative Lands Developing Countries $2.3B In Tax
A joint initiative between the Organization for Economic Cooperation and Development and the United Nations to help developing countries boost tax revenues said Monday that it has generated $2.3 billion in additional revenues and $6.05 billion in additional tax assessments since its 2015 formation.
-
April 29, 2024
Ex-Man City Player Benjamin Mendy Pays £710K Tax Debt
Former Manchester City footballer Benjamin Mendy avoided bankruptcy on Monday after paying a £710,000 ($892,000) tax bill minutes before a court hearing to determine whether an order should be made.
-
April 29, 2024
US Expatriations Plummet In 1st Quarter, IRS Says
The number of people who expatriated from the U.S. fell nearly 70% during the first quarter of 2024 compared with the previous quarter, the Internal Revenue Service said in a notice published Monday.
-
April 29, 2024
EU Official Wants Progress On New Revenue Streams
The budget commissioner of the European Union said Monday that the bloc must make progress toward agreeing on new revenue streams that would give it more diversified sources of income.
-
April 26, 2024
4 Goals For Gov'ts To Pursue In The UN Tax Convention
The United Nations' framework convention on international tax cooperation should resolve digital taxation, incorporate tax transparency conventions, seek consensus on tax allocation issues but adopt best practices by simple majority, and help fund development goals, officials and experts told Law360 as governments began negotiations Friday.
-
April 26, 2024
FedEx Calls Gov't Arguments On Tax Credits Contradictory
The federal government advanced contradictory arguments in FedEx's $84.6 million foreign tax credits dispute with the Internal Revenue Service, the package delivery giant said in a filing in Tennessee federal court.
-
April 26, 2024
Ireland Received Nearly €24B In Corp. Taxes In 2023
Corporations paid Ireland €23.8 billion ($25.5 billion) in taxes in 2023, a 5.3% increase over 2022, making corporate tax receipts the second-largest tax revenue generator in the country, according to the Irish revenue department.
-
April 26, 2024
PwC Australia Appoints 6 Partners To Guide Scandal Rebound
PwC Australia announced that it has elected six partners to its governance board as the firm continues to attempt to rebound in the wake of its scandal involving the leak of Australian government documents.
-
April 26, 2024
HMRC Says Tax Digitalization Plan Will Generate £6.4B
HM Revenue & Customs said its program to modernize U.K. tax filing is expected to generate £6.38 billion ($7.97 billion) in additional revenue through 2034 after projections last year put it at £3.9 billion.
-
April 26, 2024
Poland Seeks Input On Bill To Enact Minimum Tax
Poland, one of a handful of European Union countries that have delayed implementing the Organization for Economic Cooperation and Development's Pillar Two global minimum tax plan, introduced a proposal for public comment that would enact the regime.
-
April 26, 2024
Abbott Labs' $417M IRS Bill Isn't Wrong, Tax Court Told
The Internal Revenue Service denied allegations by Abbott Laboratories that it incorrectly increased the global healthcare giant's income, resulting in a $417 million tax bill, in answering Abbott's lawsuit filed with the U.S. Tax Court.
-
April 26, 2024
Top EU Judge Sees Lower Court Becoming Like Tax Court
The lower court of the European Union, the General Court, will over time become a venue that specializes in some tax matters after a reform is put into place, the EU's top judge has said.
-
April 26, 2024
HSBC Beats Investors' £1.3B Disney Film Scheme Fraud Case
HSBC fended off on Friday a £1.3 billion ($1.6 billion) fraud claim brought by hundreds of investors who alleged the bank misled them into financing a Disney movie tax relief scheme it developed which turned out to be worthless.
-
April 25, 2024
Romanian Sanctions On Fuel Violate EU Law, Court Says
A Romanian law imposing sanctions of €77,000 ($83,000) — 21 times the usual rate of taxation — on fuel placed back into storage is so extreme it violates European Union law, the EU's top court said Thursday.
-
April 25, 2024
Dutch Tax Authority Aiming To Beef Up Data Security
The Netherlands' tax authority is introducing more data protection measures based on suggestions from a KPMG report commissioned after signs of possible security threats within the tax administration, it said Thursday.
-
April 25, 2024
Workers' Effective Tax Rates In OECD Countries Rise Again
The effective tax rates on labor income in the majority of Organization for Economic Cooperation and Development member countries rose for the second year in a row in 2023, thanks in part to continued inflation, the OECD said Thursday.
-
April 25, 2024
OECD Says Latvia Must Shift Tax Burden, Limit Fuel Subsidies
Latvia needs to shift its tax burden off labor and onto other forms of income such as property, and to eliminate harmful subsidies and tax practices around fossil fuels, the Organization for Economic Cooperation and Development said Thursday.
-
April 25, 2024
OECD Consolidates Past Pillar 2 Guidance Into Single Doc
The Organization for Economic Cooperation and Development published administrative guidance Thursday that consolidates past publications on the interpretation and application of the international minimum tax agreement known as Pillar Two, which countries began implementing this year.
-
April 25, 2024
EU Parliament Gives Final Approval To AML Package
The European Parliament has given the final go-ahead to a package of laws to fight money laundering and terrorist financing, creating a single rule book and establishing a dedicated agency for the bloc.
-
April 25, 2024
Ministers From 4 Countries Back Billionaire Tax
Government ministers from Germany, Spain, South Africa and Brazil said Thursday that they have backed a global plan to ensure that billionaires pay a minimum amount of tax, arguing that the move is necessary to make the tax system more equitable.
-
April 24, 2024
EU Court Won't Disturb Spanish Tax Break Rulings
A Spanish company on Wednesday lost its attempt to legitimize a tax scheme declared illegal by the European Commission when the European Union's General Court rejected its appeal, refusing to disturb prior decisions in the long-running dispute.
-
April 24, 2024
GOP Reps Seek IRS Nonprofit Info After China Reports
House Ways and Means Republicans asked the Internal Revenue Service to provide information about how it monitors tax-exempt organizations for possible violations of their status after reports China may be funding and improperly influencing nonprofits, according to a letter sent Wednesday.
-
April 24, 2024
Treasury Limits Reach Of Look-Through Rule In Final Regs
The U.S. Treasury Department finalized regulations Wednesday that retain but narrow the scope of a proposal to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.
Expert Analysis
-
Attorneys, Law Schools Must Adapt To New Era Of Evidence
Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.
-
1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.
-
Tips For Litigating Against Pro Se Parties In Complex Disputes
Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.
-
Anticipating Intensified Partnership Enforcement From IRS
The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.
-
Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.
-
The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.
-
How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
-
How Law Firms Can Use Account-Based Marketing Strategies
Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.
-
Strategic Succession Planning At Law Firms Is Crucial
Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.
-
Maximizing Law Firm Profitability In Uncertain Times
As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.
-
5th Circ. Ruling Reminds Attys That CBP Can Search Devices
The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.
-
Enforcement Of International Tax Reporting Is Heating Up
Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.
-
IRS Notice Clarifies R&E Amortization, But Questions Remain
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.