International

  • December 08, 2023

    Mich. Judges Quiz Holding Co.'s Bid To Ditch Detroit Tax

    Two Michigan Court of Appeals judges sounded skeptical Friday of a holding company's arguments that it didn't owe Detroit income tax on the sale of stock in a Canada-based tobacco testing company, with one judge calling the transaction's setup "a corporate shell game."

  • December 08, 2023

    UK, Luxembourg Amend Double-Taxation Treaty

    An amended double-taxation treaty between the United Kingdom and Luxembourg, which sets forth exemptions from withholding taxes on certain kinds of income and contains new provisions on capital gains taxes, was published on the HMRC website Friday.

  • December 08, 2023

    Singapore To Tax Foreign Asset Sales As Income In 2024

    Certain gains from the sale of foreign assets by Singapore companies will be taxed as income starting in 2024, providing a revenue source and protection from tax avoidance for a country with no capital gains tax, the country's Inland Revenue Authority said Friday.

  • December 08, 2023

    Pepsi Must Pay Royalty Withholding Taxes, Aussie Court Says

    Pepsi cannot escape royalty withholding taxes on payments made between its subsidiaries in Australia and Singapore under contracts with Schweppes designed to conceal consideration for intellectual property rights, an Australian court ruled in a judgment released Friday.

  • December 08, 2023

    DC Circ. Questions Atty's Stance On Privacy Of His Tax Data

    A D.C. Circuit panel appeared skeptical Friday of an expatriate attorney's argument that the Internal Revenue Service shouldn't have released his tax information in cases where he was challenging regulations under the Tax Cuts and Jobs Act. 

  • December 08, 2023

    Norway Seeking Quick Creation Of Beneficial Owners Registry

    Norway is looking to establish a beneficial owners registry to introduce more transparency into the financial sector to better prevent crime, and it wants to do it quickly, the country's Ministry of Finance said Friday.

  • December 08, 2023

    Judge Warns Fake AI Citations May Undermine Legal System

    A U.K. tribunal warned of the "many harms" in submitting fake legal opinions generated through artificial intelligence, after finding a woman battling a tax bill submitted nine cases that did not exist to support her arguments.

  • December 08, 2023

    Vestager Not Picked For EU Bank, Will Return To Commission

    Margrethe Vestager will resume her duties as European Union competition commissioner, she said Friday after the European Investment Bank announced it had chosen Spain's economy minister as its new leader.

  • December 08, 2023

    New EU Chair Eyes Shell Law, Digital VAT Overhaul

    Belgium, in its role as incoming chair of European Union meetings, wants to move forward with a law cracking down on shell companies as well as an overhaul of value-added tax laws to move them more in line with the digital economy, the country said Friday.

  • December 07, 2023

    Microsoft Shareholders Reject Tax Transparency Plan

    Microsoft shareholders struck down a proposal for public country-by-country reporting of tax data Thursday, the latest rejection of efforts to convince investors that such transparency is inexpensive, valuable for evaluating risks and can position companies ahead of the curve.

  • December 07, 2023

    India's Top Court Says Steel Co. Is Owed $3.8M For Deduction

    An Indian steel company is entitled to an additional tax deduction of nearly 320 million rupees ($3.8 million), the Supreme Court of India ruled, agreeing with the company that the market price for calculating a tax deduction is not set by statute but between a willing buyer and seller. 

  • December 07, 2023

    OECD Tax Crime Group Considers Enforcement Network

    Tax crime experts at the OECD's Forum on Tax and Crime considered the creation of a "confidential network of tax crime law enforcement authorities" as part of larger discussions on the challenges of a digitalizing economy, the group said Thursday.

  • December 07, 2023

    Saudi Arabia Offering 30 Years Tax-Free To Corporate HQs

    Multinational corporations that establish regional headquarters in Saudi Arabia will be entirely exempt from corporate income and withholding taxes for 30 years in a move designed to entice more large companies to set up shop there, the government announced.

  • December 07, 2023

    IRS' Foreign Penalty Power Rightly Curtailed, DC Circ. Told

    A businessman who persuaded the U.S. Tax Court to declare the IRS powerless to unilaterally collect foreign-business reporting penalties asked the D.C. Circuit to let the decision stand, saying the agency is trying to regain its authority through an inapplicable part of the tax code.

  • December 07, 2023

    Deal On EU Digital VAT Law Eyed In 1st Half Of 2024

    An EU diplomat expressed hope Thursday that countries can reach a deal in the first half of next year on a package of measures to update the European Union's value-added tax rules for the digital economy.

  • December 06, 2023

    2022 Tax Revenues Fell Due To Energy Issues, OECD Says

    Excise tax cuts made in 2022 to ease high energy prices caused by the war in Ukraine lowered that year's tax revenues in most countries surveyed by the Organization for Economic Cooperation and Development, the organization said Wednesday.

  • December 06, 2023

    US Biz Group Asks To Expand Global Tax Treaty's Safe Harbor

    The threshold to participate in a safe harbor for a treaty to rewrite global tax rules on large companies should be lowered or scrapped because it risks upward transfer pricing adjustments and double taxation, a business lobby said in a letter shared Wednesday with Law360.

  • December 06, 2023

    Hong Kong To Simplify Capital Gains Qualification

    The Hong Kong Legislative Council passed a bill Wednesday that will streamline the city's system of determining whether certain gains are considered capital gains and therefore not subject to tax, the Inland Revenue Department said.

  • December 06, 2023

    OECD Exchange Of Information Program Has Trained 5,800

    An OECD-led program to coach tax officials on teaching others about international exchanges of information standards has led to more than 5,800 people in 65 Global Forum jurisdictions being trained so far, the group announced Wednesday.

  • December 06, 2023

    11th Circ. Questions Whether $18M FBAR Penalty Is Excessive

    The Eleventh Circuit questioned Wednesday whether $18 million in tax penalties against a man who failed to report his foreign bank accounts may have breached the U.S. Constitution's bar on excessive fines, with one judge calling the issue the most serious in the case.

  • December 06, 2023

    Mayer Brown Questions Retroactivity Of Repatriation Regs

    The U.S. Treasury Department's proposed changes to regulations regarding the repatriation of foreign earnings go too far, particularly in how far back they would retroactively apply, Mayer Brown LLP told the Internal Revenue Service in a letter published Wednesday.

  • December 06, 2023

    EU, Norway Update Agreement To Combat VAT Fraud

    The European Commission and Norway reached an agreement Wednesday strengthening their pact to mutually combat value-added tax fraud by updating it to include newer standards created by the European Union.

  • December 06, 2023

    Indictment Filed In €2.2B European VAT Fraud Scheme

    The European Public Prosecutor's Office filed an indictment Wednesday against suspects in a VAT fraud ring that it said operated in over 30 countries and led to an estimated €2.2 billion ($2.37 billion) in lost revenue by abusing EU rules on cross-border transactions between member states.

  • December 06, 2023

    A&O Says Nationwide's Negligence Led To £75M Tax Bill

    Allen & Overy LLP has denied owing Nationwide Building Society £75 million ($94 million) in tax liability for failing to submit applications to list notes on the London Stock Exchange, saying that the loss was a result of the lender's own negligence.

  • December 06, 2023

    UAE Extradites British Trader To Denmark In Tax Fraud Case

    Sanjay Shah has been extradited from the United Arab Emirates to Denmark, where the British hedge fund trader is wanted by Danish authorities for allegedly masterminding a £1.44 billion ($1.8 billion) tax fraud scheme, his lawyers said Wednesday.

Featured Stories

  • Narrow Ruling Expected In Justices' Repatriation Tax Review

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    Several tax law experts expect a narrow ruling on the constitutionality of the one-time repatriation tax after the U.S. Supreme Court justices signaled they were cognizant of the tax code consequences a broad ruling could have.

  • US Trade Tensions With Canada Spark Defense Of DSTs

    Natalie Olivo

    The U.S. government's threats of retaliatory trade measures in response to Canada's proposed digital services tax have drawn criticism from specialists, who say certain DSTs aren't inherently discriminatory and are a relatively feasible way for countries to tax revenue generated online.

  • Former Clerks Say Justice O'Connor Still Worth Emulating

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    BigLaw attorneys mentored by former U.S. Supreme Court Justice Sandra Day O'Connor, who died Friday after a lengthy battle with dementia, say she'll be remembered as an incisive jurist who always put facts and practical considerations above abstract ideological commitments, as well as a deeply gracious and down-to-earth woman who never let her dedication to the law overshadow her zest for life.

Expert Analysis

  • 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.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    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

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    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

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    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.