International

  • July 19, 2024

    Attorney Denied Separate Trial In $2.1B Danish Tax Fraud

    An attorney facing trial alongside his clients for alleged ties to a $2.1 billion Danish tax fraud has been denied a separate hearing by a New York federal court, which remained unconvinced that his co-workers' advice to the clients could rebound on him prejudicially in a joint trial.

  • July 19, 2024

    Taxation With Representation: A&O Shearman, Gibson Dunn

    In this week's Taxation With Representation, Cleveland-Cliffs Inc. buys Stelco Holdings Inc., KBR acquires LinQuest Corp., Blue Owl Capital Inc. purchases Atalaya Capital Management LP, and Amphenol Corp. buys two mobile networks units from CommScope.

  • July 19, 2024

    2 Arrested In €8.8M VAT Fraud Involving Cleaning Products

    Italian financial police arrested two people Friday who are suspected of leading an €8.8 million ($9.6 million) value-added tax fraud scheme involving cleaning products and beverages, the European Public Prosecutor's Office said.

  • July 19, 2024

    Gov't Floats Draft Proposal For OBR 'Fiscal Lock' Powers

    HM Treasury proposals for a new "fiscal lock" in a draft Budget Responsibility Bill will allow the Office for Budget Responsibility to scrutinize any tax-and-spend decisions with a cost factor of 1% of gross domestic product or more.

  • July 19, 2024

    International Tax Policy To Watch In The 2nd Half Of 2024

    An abundance of loose threads pervades the international tax landscape as the first year of the global minimum tax unfolds, with the battle over digital services taxes still smoldering and diplomats talking tougher taxes on the wealthy. Here, Law360 looks at international tax policy to watch in the second half of 2024.

  • July 19, 2024

    EU Parliament's Tax Body To Elect Chair On July 23

    The European Parliament's subcommittee on taxation is due to elect its chair and vice chairs when it meets on July 23, the Parliament confirmed in a statement on Friday.

  • July 18, 2024

    Treasury Starting To Address Amount B, Official Says

    The U.S. Department of the Treasury is just starting to decide how to handle a transfer pricing regime under a prong of the OECD-led global tax overhaul, a Treasury official said Thursday.

  • July 18, 2024

    Tax Pros Say Gov'ts Stretching 'Realistic Alternative' Analysis

    Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.

  • July 18, 2024

    Ex-Venable Trusts And Estates Partner Joins Stradling In LA

    Stradling Yocca Carlson & Rauth PC announced that it launched a trusts and estates practice with the hiring of an experienced Los Angeles-based partner from Venable LLP.

  • July 18, 2024

    Most Top US Cos. To Report Tax Under Aussie Bill, Study Says

    Australia's Senate is expected to consider adoption next month of the world's most extensive public country-by-country reporting rules, which would require 51% of large U.S. multinational corporations to disclose tax arrangements retroactively from July 1, according to a study published Thursday.

  • July 18, 2024

    UK Brothers Sentenced For £3.2M Offshore Tax Evasion

    A pair of brothers each received suspended two-year prison sentences for charges related to a tax evasion scheme where they hid more than £3.2 million ($4.1 million) using companies in Gibraltar and the British Virgin Islands, HM Revenue & Customs said Thursday.

  • July 18, 2024

    Rising Star: Latham's Eric Kamerman

    Eric Kamerman of Latham & Watkins LLP in recent years handled the tax aspects of several multibillion-dollar acquisitions of powerhouses in British soccer and American fashion, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.

  • July 18, 2024

    GE Can't Claim Credit For £189M In Double Tax, Court Says

    A U.K.-registered subsidiary of General Electric does not qualify for at least £189 million ($245 million) in double tax relief under a U.S.-U.K. treaty because it lacks a U.S. presence akin to a domicile, a London appellate court ruled.

  • July 17, 2024

    Much Of Pillar 1 Treaty Agreed On, OECD Official Says

    Agreement has been reached on the bulk of a multilateral pact to implement new taxing rights that are part of a revamp of the international tax system and on expansions to a part of the taxing rights plan, an OECD official said Wednesday.

  • July 17, 2024

    Gov't Views On OECD Risk Guidance Vary, Economists Say

    In allocating risk among different components of a business for transfer pricing purposes, analysts need to consider governments' varying interpretations of guidance from the Organization for Economic Cooperation and Development, a panel of economists said Wednesday.

  • July 17, 2024

    Aussie Gov't Seeks Tighter Promoter Penalties After PwC Leak

    Australia is poised to penalize a wider range of advisers who promote tax schemes to multinational corporations and beef up its Tax Practitioners Board's ability to investigate cases after it uncovered PwC sharing confidential draft laws with clients, according to a consultation that began Wednesday.

  • July 17, 2024

    Germany Sends Budget With €23B In Tax Cuts To Parliament

    Germany's executive body approved a legislative package Wednesday that includes €23 billion ($25.2 billion) in tax cuts for citizens and companies across the next two years, sending it to the country's parliament for consideration.

  • July 17, 2024

    Disney To Join IBM's Bid To Bring NY Tax Fight To Justices

    The Walt Disney Co. joined IBM in asking the U.S. Supreme Court for more time to file a petition for review of a New York high court decision that upheld tax on royalties received from foreign affiliates.

  • July 17, 2024

    Connell Foley Adds Wilson Elser Tax Pro In Group Upgrade

    Connell Foley LLP strengthened its tax and estate team this week with the promotion of several attorneys up to partner and the addition of a mergers and acquisitions and corporate restructuring tax expert previously of counsel at Wilson Elser Moskowitz Edelman & Dicker LLP.

  • July 17, 2024

    2 Arrested In €7.6M Italian VAT Fraud Scheme

    Financial police in Italy arrested who authorities said were two main suspects in a scheme involving sales of luxury cars that evaded €7.6 million ($8.3 million) in value-added taxes, the European Public Prosecutor's Office said Wednesday.

  • July 17, 2024

    IRS Plans August Hearing On Stock Buyback Tax Rules

    The Internal Revenue Service will hold a public hearing Aug. 27 on proposed regulations governing a new excise tax on repurchases of corporate stock, the agency said Wednesday.

  • July 17, 2024

    Rising Star: Cravath's Kiran Sheffrin

    Kiran Sheffrin of Cravath Swaine & Moore LLP has advised companies from Anheuser-Busch InBev to Valvoline on multibillion-dollar deals, including a $50 billion combination resulting in the formation of pharmaceutical giant Viatris, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 17, 2024

    Woman Can't Escape Suit Over Partner's $1.1M FBAR Debt

    A woman whose late romantic partner owed $1.1 million in reporting penalties on hidden financial accounts in France and Switzerland can't stop the government from pursuing a suit against her for half the value of her home, a New York federal court ruled.

  • July 17, 2024

    Baker McKenzie Adds EY Partner To Mexico City Office

    Baker McKenzie has appointed a new partner from EY Mexico to its North American tax practice group in Mexico City.

  • July 17, 2024

    Estonia Expects Solutions From EU Chair On VAT Law

    Estonia said Wednesday that it expects "constructive solutions" from the current chair of European Union meetings regarding changes to value-added tax law, which Estonia blocked during meetings of EU finance ministers in May and June.

Featured Stories

  • International Tax Policy To Watch In The 2nd Half Of 2024

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    An abundance of loose threads pervades the international tax landscape as the first year of the global minimum tax unfolds, with the battle over digital services taxes still smoldering and diplomats talking tougher taxes on the wealthy. Here, Law360 looks at international tax policy to watch in the second half of 2024.

  • Top International Tax Cases To Watch In The 2nd Half Of 2024

    Natalie Olivo

    Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.

  • 3 Tax Reg Groups That May Be Shaky After High Court Rulings

    Natalie Olivo

    The U.S. Supreme Court issued two rulings that, when combined, open up long-standing federal regulations to challenges without judicial deference to agencies — a pairing that could weaken several categories of tax rules, including guidance issued under the 2017 federal overhaul. Here, Law360 looks at three batches of tax regulations that may be vulnerable in the aftermath of the high court's decisions.

Expert Analysis

  • Now More Than Ever, Lawyers Must Exhibit Professionalism

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    As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.

  • Atty Well-Being Efforts Ignore Root Causes Of The Problem

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    The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.

  • Unpacking The Circuit Split Over A Federal Atty Fee Rule

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    Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.

  • After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1

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    The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.

  • Recruitment Trends In Emerging Law Firm Frontiers

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    BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.