International

  • July 16, 2024

    BREAKING: Top UK Court Rules Deal Advice Fees Are Not Tax Deductible

    Britain's Supreme Court ruled Tuesday that £2.5 million ($3.2 million) paid in advisory fees by an investment company to Deutsche Bank and others is not tax-deductible as the expenses were "capital in nature" spent trying to dispose of a Dutch business.

  • July 15, 2024

    CarMax Distorted SC Activity To Lower Taxes, Judge Says

    CarMax Auto Superstores Inc. used intercompany transactions to distort an entity's business activity and thus its tax burden in South Carolina, an administrative law judge ruled, finding the company should have used an alternative apportionment method to properly calculate income.

  • July 15, 2024

    Distributions Were Not Dividends, Canada Tax Court Says

    Distributions to shareholders after the sale of a Canadian video game company were properly taxed as employee benefits instead of dividends, the Tax Court of Canada ruled.

  • July 15, 2024

    Israeli Firm Seeks To Amend Suit Against GILTI Regs

    The owner of an Israeli law firm asked a D.C. federal court to let him amend his challenge to regulations for the U.S. tax on global intangible low-taxed income after the D.C. Circuit determined parts of his arguments went unconsidered.

  • July 15, 2024

    Former Doctor Seeks Jail Release In FBAR Fight

    An incarcerated former doctor asked a Michigan federal court Monday to lift its order of civil contempt for his failure to pay about $1 million in foreign account reporting penalties, saying he has done all he can to repatriate offshore securities.

  • July 15, 2024

    Widow To Pull $1.7M From Swiss Bank To Pay FBAR Penalties

    A logger's widow agreed to pull about $1.7 million from her Swiss bank account to pay down penalties that her late husband's estate owes the IRS for his failure to report offshore accounts, according to a filing Monday in a Colorado federal court.

  • July 15, 2024

    AICPA Suggests Revising Foreign Trust Loan Anti-Abuse Rule

    The U.S. Treasury Department should scrap or revise significantly an anti-abuse rule for nonresident aliens who receive loans from foreign trusts, which was included in proposed regulations on how to report foreign trust transactions, the American Institute of Certified Public Accountants said in a letter published Monday.

  • July 15, 2024

    Aussie Hydrogen Tax Credit Should Be Doubled, Group Says

    Australia's proposed hydrogen production tax incentive, which would allow eligible projects to claim a credit worth AU$2 ($1.35) per kilogram of renewable hydrogen, should be doubled, a business group said in a set of recommendations on the plan.

  • July 15, 2024

    Akerman Brings On Chamberlain Hrdlicka Tax Pros In Atlanta

    Akerman LLP announced Monday that it picked up a pair of new partners for its tax practice group in Atlanta who were previously with Chamberlain Hrdlicka White Williams & Aughtry.

  • July 15, 2024

    3 Arrested In German Probes Of €8.6M VAT Fraud Rings

    Three suspects have been arrested in German-led investigations of two fraud rings involving the security and surveillance industry that evaded a total of €8.6 million ($9.4 million) in value-added taxes, Hamburg's tax authority announced Monday.

  • July 15, 2024

    Bermuda Proposes New Agency For Corp. Taxation

    Bermuda's Legislature will consider a proposal to establish a Corporate Income Tax Agency to administer the island nation's corporate income tax regime, including its recently enacted 15% global corporate minimum tax on large multinational corporations.

  • July 15, 2024

    Rising Star: Davis Polk's Dominic Foulkes

    Dominic Foulkes of Davis Polk & Wardwell LLP has advised companies on several multibillion-dollar transactions, including a technology-maker's $4.9 billion initial public offering, the largest in the United States in the last three years, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 15, 2024

    German Minister To Study Findings On Simplifying Tax

    Germany's finance minister said Monday in a news release that ideas on tax law put forward in two expert reports submitted last week would be looked at in detail, adding that any simplifications to the tax system should reduce the burden on citizens.

  • July 15, 2024

    EU's Top Court Asked To Rule On Refund Of VAT In Bulgaria

    A Bulgarian court asked the European Union's highest court to determine whether a company in the country can receive a refund of value-added tax paid for devices when the devices did not leave the territory of another EU country, a document published Monday said.

  • July 12, 2024

    Rising Star: Quinn Emanuel's Emily Au

    Emily Au of Quinn Emanuel Urquhart & Sullivan LLP has been the lead attorney on several high-profile cases, including a key case across the U.K. construction industry in terms of HMRC's Value-Added Tax policy, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 12, 2024

    Law360 Names 2024's Top Attorneys Under 40

    Law360 is pleased to announce the Rising Stars of 2024, our list of 158 attorneys under 40 whose legal accomplishments belie their age.

  • July 12, 2024

    Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.

    The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.

  • July 12, 2024

    Parliament Vote On Von Der Leyen's 2nd Term Coming July 18

    The European Parliament will vote July 18 whether to approve current European Commission President Ursula von der Leyen for a second five-year term, according to a document published Friday.

  • July 12, 2024

    Switzerland, Hungary Adding Anti-Abuse Clause To Tax Treaty

    Switzerland and Hungary moved on Friday to add to their double-taxation treaty an anti-abuse clause that prevents a person who is not a resident of either country from claiming the benefits of the treaty.

  • July 12, 2024

    Taxation With Representation: Ropes & Gray, Cravath, Latham

    In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s property tax business, and Bain Capital buys Envestnet Inc.

  • July 12, 2024

    Alvarez & Marsal Appoints Managing Director Of Tax Group

    Alvarez & Marsal Tax LLC appointed an experienced negotiator of tax incentives as managing director to the firm's corporate transformation tax group, the firm announced.

  • July 12, 2024

    EU Chair Doesn't Expect Energy Tax Deal This Year

    The new chair of European Union finance ministers doesn't expect to reach agreement on a landmark energy taxation law in the next half-year, anticipating only exploratory talks, an official from Hungary's EU presidency said Friday.

  • July 11, 2024

    House GOP Urges USTR To Probe Canada Digital Services Tax

    The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.

  • July 11, 2024

    ABA Attys Seek To Avoid Reporting Foreign Trust Loans

    The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.

  • July 11, 2024

    Brazilian Tax Agency Probes Refund Fraud Scheme

    Brazilian federal tax authorities and police said Thursday they had conducted a search-and-seizure operation related to the investigation of an income tax refund fraud scheme.

Featured Stories

  • French Left's Tax Pledges May Go Unfulfilled

    Todd Buell

    The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.

  • Top International Tax Cases Of 2024: Midyear Report

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    With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.

  • How Reshaped Circuit Courts Are Faring At The High Court

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    Seminal rulings from the U.S. Supreme Court's latest term will reshape many facets of American society in the coming years. Already, however, the rulings offer glimpses of how the justices view specific circuit courts, which have themselves been reshaped by an abundance of new judges.

Expert Analysis

  • 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.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.