International

  • May 14, 2024

    Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight

    The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.

  • May 14, 2024

    Solarium Sunbaths Not Tax-Free Wellness, Sweden Says

    After receiving multiple questions about whether paying to sunbathe in a solarium is eligible for Sweden's tax-free wellness allowance, the country's tax agency said Tuesday that such activity is not eligible.

  • May 14, 2024

    Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'

    An Internal Revenue Service supervisor's sign-off on a transfer pricing penalty for Microsemi was "woefully inadequate" to meet statutory requirements for penalty approval, the semiconductor manufacturer told the U.S. Tax Court.

  • May 14, 2024

    Aussie Budget Proposes Green Credits, Capital Gains Change

    Australia would offer tax credits for hydrogen production and critical mineral mining and update its foreign resident capital gains tax rules as part of a proposed 2024-25 budget released Tuesday.

  • May 14, 2024

    British Industry Group Calls For Green Energy Tax Breaks

    The U.K. needs to "outsmart rather than outspend" other countries to grow in the green energy sector, a British business advocacy group said, calling for the government to create a 40% so-called green innovation tax credit, among other tax breaks.

  • May 14, 2024

    Ex-Whiteford Taylor Business Co-Chair Joins Baker Donelson

    Baker Donelson Bearman Caldwell & Berkowitz PC has welcomed a new shareholder who spent more than a decade with the Internal Revenue Service and previously co-chaired Whiteford Taylor & Preston LLP's business department, the firm announced on Monday.

  • May 14, 2024

    EU Finance Ministers Strike Deal On Withholding Tax Refunds

    European Union finance ministers agreed Tuesday to a withholding tax refund law, as previous holdouts Poland and the Czech Republic withdrew their objections.

  • May 14, 2024

    EU Chair To Fight On For VAT Deal After Estonia's Rejection

    The chair of the European Union's council of finance ministers said he will fight to get unanimous support for a wide-ranging reform of value-added tax rules after Estonia blocked agreement to the law Tuesday.

  • May 14, 2024

    Aussie Senate Faces Separation Of Promoter Penalty, Gas Tax

    The Australian government is poised to double the penalty for corporate promoters of tax avoidance schemes, but it may first have to compromise by separating its bill from another one dealing with a tax on offshore gas exports, according to a legislative report.

  • May 13, 2024

    Corp. Transparency Act An Overbroad Dragnet, 11th Circ. Told

    Congress exceeded its authority in passing the Corporate Transparency Act, which prompted the U.S. Treasury Department to solicit personal information for law enforcement purposes from those that registered and owned state-registered entities, a small-business group told the Eleventh Circuit on Monday.

  • May 13, 2024

    House GOP Bills Target Foreign Funding To Tax-Exempt Orgs

    The House Ways and Means Committee will vote Wednesday on a package of bills that would increase scrutiny of foreign donations to tax-exempt organizations, including legislation that would require those organizations to publicly report the donations, the Joint Committee on Taxation announced Monday.

  • May 13, 2024

    Income Nixes Exxon's 'Final Loss' Deduction, Court Says

    Exxon's Norwegian operation cannot deduct 900 million krone ($83.2 million) from its fiscal year 2012 taxable income that it spent liquidating an Exxon subsidiary in Denmark, a European court ruled Monday.

  • May 13, 2024

    2nd Circ. Won't Revive UBS Suit Over Disclosed Account Info

    The Second Circuit declined Monday to revive a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service, finding that any alleged harm resulting from an audit would have been caused by the agency itself.

  • May 13, 2024

    Int'l Authorities Want Increased Anti-Money Laundering Efforts

    Countries need to do more to tackle the "huge illicit profits" being generated by international crime organizations and used for harmful practices such as funding terrorism, the heads of the Financial Action Task Force, Interpol and a United Nations group said Monday.

  • May 13, 2024

    Estonia Needs To Improve Property, Health Taxes, OECD Says

    While Estonia has the lowest ratio of government debt to gross domestic product of any OECD country, it has numerous areas where it could improve its tax system, from broadening its tax base to increasing healthcare funding, the OECD said Monday.

  • May 13, 2024

    EU Initiative Pushes Bloc To Strengthen Carbon Taxing

    The European Commission on Monday officially registered a citizen initiative to focus on accelerating the taxing of greenhouse gas emissions as well as making it more equitable, giving the group behind it a year to meet certain criteria that would force the European Union's executive arm to act.

  • May 13, 2024

    Houston Truck Co. Doesn't Owe $2M Excise Tax, 5th Circ. Told

    A Houston truck company that sells tires made by a Chinese manufacturer doesn't owe $2 million in import taxes because it's not legally the tire importer, the company told the Fifth Circuit in asking it to affirm a ruling that could split circuits.

  • May 13, 2024

    Estonia Objecting To VAT Proposal On 'Neutrality' Grounds

    Estonia is objecting to a proposed overhaul of European Union value-added tax rules because the proposal doesn't respect the principle of "neutrality," the country's finance minister said Monday, casting doubt on the fate of the proposal, which needs agreement by all 27 EU countries to pass.

  • May 13, 2024

    EU Chair Offers Compromise To Clinch Withholding Tax Deal

    The chair of European Union finance ministers offered last-minute concessions to try to persuade holdouts the Czech Republic and Poland to agree to a withholding tax refund law, a document published Monday showed.

  • May 11, 2024

    Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment

    The U.S. government asked the Eighth Circuit to uphold a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from 3M's Brazilian affiliate, arguing the company's appeal involves misplaced reliance on a U.S. Supreme Court decision.

  • May 10, 2024

    5 Goals Gov'ts Have For The UN Tax Convention

    Transfer pricing, country-by-country reporting, wealth taxation, the digital economy and the participation of developing countries in negotiations are topics governments at the United Nations said they want to address during the first session on drafting terms of reference for the Framework Convention on International Tax Cooperation.

  • May 10, 2024

    Austria Eyes Fines For Fake Invoices Used In Tax Fraud

    People creating false invoices in Austria could face fines of up to €100,000 ($108,000) as the country looks to crack down on tax fraud involving fictitious businesses, the country's Ministry of Finance said Friday.

  • May 10, 2024

    DC Tax Atty Can't Use Ch. 7 To Ditch Depo In $19M Theft Suit

    A corporate D.C. tax attorney accused of bilking a former client out of $19 million via a captive insurance scam will be deposed, despite a stay in the Maryland federal case against him and his firm after both filed for bankruptcy.

  • May 10, 2024

    Use Of AI For Tax Comment Letters Poses Ethical Quandaries

    While artificial intelligence can streamline the process of conducting a comprehensive review of complex, IRS-proposed federal tax regulations, tax attorneys must be aware of professional and ethical considerations when using it to help draft comment letters to submit to the agency.

  • May 10, 2024

    Australia Looks To Tweak Tax Exemption For US Entertainers

    Australia wants public comments on a proposal that would simplify the elimination of withholding taxes for U.S. entertainers who make $10,000 or less — or the Australian equivalent — in the country in a given year, the Australian Taxation Office said.

Expert Analysis

  • 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.

  • 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.

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