International

  • May 23, 2024

    White & Case Adds Former A&O Tax Pro In Luxembourg

    White & Case LLP announced it has added a tax partner to its Luxembourg office from A&O Shearman who specializes in international and Luxembourg corporate tax law.

  • May 23, 2024

    Carbon Pricing Generated Over $100B In 2023, Report Says

    Carbon pricing mechanisms worldwide generated a record $104 billion in revenue in 2023, according to a World Bank report, though it said the 75 instruments currently in force are too few and doing too little.

  • May 23, 2024

    Spain, Greece, Sweden Have Tax Policy Problems, EU Says

    The European Union's executive arm called on Spain, Greece and Sweden on Thursday to change tax laws the bloc finds problematic, while also referring a Spanish tax issue to the European Court of Justice.

  • May 23, 2024

    EU Flags Nations For Shortcomings On Pillar 2, Exchange Law

    The European Commission said Thursday that six European Union countries still have failed to implement the global minimum tax for large companies, and it noted that an additional three aren't properly implementing an information exchange law.

  • May 23, 2024

    Yellen Opposes Global Redistribution Of Billionaires' Wealth

    U.S. Treasury Secretary Janet Yellen repeated Thursday that she opposes a global minimum tax on billionaires and added that she does not support basing a redistribution of the revenue from such a tax on damage from climate change and related financing needs.

  • May 23, 2024

    G7 Should Agree On Frozen Russian Assets, Yellen Says

    U.S. Treasury Secretary Janet Yellen said Thursday that the Group of Seven countries should agree now on a concept of how the capital of frozen and immobilized Russian state assets should be used to support Ukraine's war against Russia.

  • May 23, 2024

    EU Could Add Sectors To Border Tax, Commissioner Says

    The European Union should consider expanding its carbon border tax beyond the initial sectors covered, an EU commissioner has said.

  • May 23, 2024

    Akerman Brings On Kilpatrick Tax Ace In LA

    Akerman LLP is boosting its tax team, bringing in a Kilpatrick Townsend & Stockton LLP corporate tax and energy tax credit expert as a partner in its Los Angeles office.

  • May 22, 2024

    Justices' CFPB Alliance May Save SEC Courts, Not Chevron

    A four-justice concurrence to the U.S. Supreme Court's decision upholding the Consumer Financial Protection Bureau's unique funding scheme last week carries implications for other cases pending before the court that challenge the so-called administrative state, or the permanent cadre of regulatory agencies and career government enforcers who hold sway over vast swaths of American economic life.

  • May 22, 2024

    German Legislature Moves To Update Certain Tax Treaties

    The lower house of Germany's legislature has approved a bill to update multiple bilateral tax treaties as part of the country's implementation of the Organization for Economic Cooperation and Development's project against base erosion and profit shifting.

  • May 22, 2024

    Doctor Must Stay In Jail In Tax Penalty Fight, Gov't Says

    A doctor incarcerated for civil contempt for not paying $1.1 million in penalties for failing to report his foreign accounts should remain in jail until he has done more to comply, the U.S. government told a Michigan federal court Wednesday.

  • May 22, 2024

    Belgium Provides Pillar 2 Reporting Rules

    Belgium's finance ministry has issued guidance on what large multinational entities and domestic groups will need to do to comply with the country's coming registration requirement as part of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax.

  • May 22, 2024

    Guernsey Joins Crown Dependencies Moving Toward Pillar 2

    Guernsey will soon take steps to implement the OECD's 15% global minimum tax on large multinational corporations making €750 million ($813 million) annually, in line with fellow U.K. crown dependencies the Isle of Man and Jersey, the island's Finance Ministry said.

  • May 22, 2024

    Property Transfer For Tax Break Not Dishonest, UK Court Says

    Two liquidated London real estate companies failed to convince the United Kingdom Court of Appeal that their former director behaved dishonestly by transferring their holdings to Jersey trusts for less than market value to obtain a tax advantage, according to a judgment released Wednesday.

  • May 22, 2024

    IRS Again Delays Reporting Rules for Certain BEAT Payments

    The Internal Revenue Service is deferring until 2027 the applicability date of requirements for reporting certain intercompany payments that are exempt from the base erosion and anti-abuse tax, the agency announced Wednesday.

  • May 22, 2024

    IRS Again Delaying Dividend Anti-Abuse Regs

    The Internal Revenue Service is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, it announced Wednesday.

  • May 22, 2024

    UK Gov't Calls Elections For July 4 Despite Poor Polls

    Prime Minister Rishi Sunak on Wednesday called an early general election to be held on July 4, advancing the electoral timetable even though his Conservative Party lags decisively behind the opposition Labour Party.

  • May 22, 2024

    Swiss Gov't Adopts Proposals For Tougher AML Laws

    Switzerland on Wednesday approved a new anti-money laundering framework that will introduce a register in which companies and other legal entities in the country will have to disclose information on their beneficial owners in a major shift in its anti-money laundering rules.

  • May 22, 2024

    EU's Carbon Border Tax Pushes Others To Follow, Experts Say

    The European Union's carbon border tax is pushing many countries outside the bloc to introduce similar systems, government and academic experts said Wednesday.

  • May 22, 2024

    UK Dependency To Implement Pillar 2 Starting In 2025

    The island of Jersey, a U.K. crown dependency, said it would implement the international minimum tax for large corporations known as Pillar Two, with the law taking effect next year.

  • May 21, 2024

    Nixing Green Energy Tax Perks Would Be Tough For Trump

    Former President Donald Trump has vowed to scrap Democrats' signature 2022 climate law should he get reelected in November, but following through on that campaign promise could prove difficult amid bipartisan support for many of the law's clean energy tax incentives and a potentially divided Congress.

  • May 21, 2024

    Wyden Expands Pharma Tax Investigation With Pfizer Inquiry

    Senate Finance Committee Chairman Ron Wyden asked Pfizer to provide details on its tax practices to explain how the drug company has consistently paid tax rates that are significantly lower than the corporate tax rate in a letter released by the committee Tuesday.

  • May 21, 2024

    CohnReznick Adds PwC Partner To International Tax Practice

    CohnReznick has a new principal in its international tax practice who previously served as a partner at PwC, the firm announced.

  • May 21, 2024

    22 States Tell 11th Circ. Corp. Transparency Act Goes Too Far

    The federal Corporate Transparency Act unconstitutionally displaces state authority and its enforcement would economically harm states and their residents, attorneys general from 22 states told the Eleventh Circuit, urging it to uphold a ruling that struck down the law.

  • May 21, 2024

    Yellen Says US Can't Support Global Tax On Billionaires

    Treasury Secretary Janet Yellen said the U.S. can't support Brazil's proposal for the Group of 20 nations to endorse pursuing a multilateral agreement to tax billionaires' wealth at a minimum rate.

Expert Analysis

  • 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.

  • Anticipating Intensified Partnership Enforcement From IRS

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    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

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    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'

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

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