International
-
May 02, 2025
IRS Updates Rates For Foreign Insurance Company Equations
The Internal Revenue Service on Friday published updated domestic asset/liability and yields percentages for 2024 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.
-
May 02, 2025
Taxation With Representation: Goodwin, Haynes Boone
In this week's Taxation With Representation, Merck buys SpringWorks Therapeutics, Novartis AG acquires Regulus Therapeutics Inc., Sabre Corp. sells its Hospitality Solutions business to private equity shop TPG, and TWG Global and Mubadala Capital team up to bolster their investments.
-
May 02, 2025
Community Groups Accept Pause In CTA Litigation
A group of community associations has told the Fourth Circuit they aren't opposed to a government motion to pause litigation over the Corporate Transparency Act, even as they maintained the information disclosure law aimed at small businesses still carries constitutional flaws.
-
May 01, 2025
Irish Tax Appeals Board Closed €355M In Cases In 2024
Ireland's Tax Appeals Commission closed more than 1,711 appeals cases in 2024, a 12% increase over the year prior and valued at €355 million ($401 million) in taxes, the commission said in a report.
-
May 01, 2025
Multinationals Grapple With Tariff-Induced Pricing Issues
President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.
-
May 01, 2025
Trump Picks Tax Controversy Pro For IRS Chief Counsel Spot
President Donald Trump has tapped a former Internal Revenue Service chief counsel to return to the role, and if he is confirmed, it will represent the second time in his career that the veteran tax controversy professional will be the agency's top attorney.
-
May 01, 2025
Chilean Digital Platforms Must Show Users' Tax Compliance
Digital platforms operating in Chile will need to show that those either contracting their services or using them to offer their owns goods and services are tax-compliant starting in 2026, Chile's tax administration said.
-
May 01, 2025
Canada Looks To Guide Exporters Navigating US Tariffs
The Canadian government is offering new resources for exporters dealing with what it called unjustified U.S. tariffs, providing information on rules of origin and customs procedures under the U.S.-Canada-Mexico Agreement.
-
May 01, 2025
Estate Pushes Back On IRS In DC Circ. Lost Records Case
The estate of a man whose offshore businesses were raided by the IRS, giving rise to a nearly $18 million tax judgment, criticized the agency's effort to rebuff the estate's claims to the D.C. Circuit that the IRS fraudulently claimed that boxes of evidence in ensuing litigation were lost.
-
May 01, 2025
Ore. Tax Court Retains Nix Of Microsoft Foreign Income Relief
The Oregon Tax Court is adhering to its finding on the treatment of Microsoft's repatriated foreign income when calculating its state income, making only minor changes to an earlier order and rejecting the company's arguments for further relief.
-
May 01, 2025
ECB Says Consumers Ready To Avoid US Goods Over Tariffs
European consumers are prepared to avoid American goods for the long term, following the impact of tariffs imposed by the U.S. administration, according to a survey by the European Central Bank.
-
May 01, 2025
BNY Can't Escape A&O Shearman's £93M Negligence Claim
Bank of New York Mellon lost its fight Thursday to escape a claim from Allen Overy Shearman Sterling alleging that the lender caused Nationwide Building Society to face a £93 million ($109 million) tax bill by bungling the issuance of notes.
-
April 30, 2025
Senate Rejects Bill To End Trump's Nat'l Emergency On Tariffs
The U.S. Senate narrowly rejected a bipartisan bill Wednesday that sought to end the national emergency declared by President Donald Trump to underpin his global tariff regime, with two senators absent for the vote, and with U.S. House consideration delayed until October.
-
April 30, 2025
Workers' Effective Tax Rates In OECD Up Again, But So Is Pay
While the effective tax rates on labor across the Organization for Economic Cooperation and Development's 38 member countries on average ticked up for a third year in a row in 2024, average wages were up in all but four countries after dropping over the prior two years, the OECD said Wednesday.
-
April 30, 2025
US Economy Shrank 0.3% In First Quarter As Imports Surged
U.S. gross domestic product fell at an annual rate of 0.3% in the first quarter of 2025 as importers stockpiled goods in advance of President Donald Trump's global tariff regime, the U.S. Department of Commerce announced Tuesday.
-
April 30, 2025
EU Busts $10M VAT Fraud Ring Involving Chinese Imports
The European Anti-Fraud Office and Polish authorities uncovered a value-added tax fraud ring that exploited European Union rules to dodge over 38.2 million Polish zloty ($10.1 million) in value-added taxes on goods imported from China, they said Wednesday.
-
April 30, 2025
Morgan Lewis Expands Tax Practice With Milbank Hire
Morgan Lewis & Bockius LLP added a former Milbank special counsel as a tax partner based in the firm's London office.
-
April 30, 2025
Dentist Fights HMRC Over Alleged Tax Avoidance
A dentist's firm urged an appeals court on Wednesday to find that it had not engaged in tax avoidance by making loan payments to its owner through a trust, saying the payments had no connection to its owner's employment and therefore were not taxable as income.
-
April 30, 2025
Switzerland Begins Consultation On Pillar 2 Return Rules
The Swiss government said Wednesday that it has begun the consultation process to create compliance rules for a global information return that companies must submit as part of an international minimum corporate tax agreement known as Pillar Two.
-
April 30, 2025
Sheppard Mullin Brings On Kirkland Tax Ace In Houston
Sheppard Mullin Richter & Hampton LLP announced Wednesday that it expanded its tax, employee benefits and trusts and estates practice with a new partner most recently with Kirkland & Ellis LLP.
-
April 30, 2025
Dem Reps. Urge Court To Block IRS-ICE Info-Sharing Pact
House Democrats and two organizations that help immigrants prepare tax returns urged a D.C. federal court to block the Internal Revenue Service from sharing with immigration enforcement agencies the names and addresses of people suspected of being in the country illegally.
-
April 30, 2025
Fried Frank Taps Sidley's UK Tax Head
The former head of Sidley Austin LLP's U.K. tax practice has joined Fried Frank Harris Shriver & Jacobson LLP's London office, where he will advise on U.K. and international tax structuring, the firm announced.
-
April 30, 2025
Ex-Treasury Official Joins Baker McKenzie's Tax Practice
Baker McKenzie has hired a former deputy assistant secretary at the Treasury Department to work on international tax matters as a partner in the firm's office in Washington, D.C.
-
April 30, 2025
HMRC Should Use AI To Boost Services, Report Says
HM Revenue & Customs is still not doing enough to improve its services and should prepare to use artificial intelligence to enhance customer service for U.K. taxpayers and increase its productivity, according to a parliamentary report.
-
April 29, 2025
Immigration Ruling No Help To Liberty Global, 10th Circ. Told
Liberty Global cannot use a U.S. Supreme Court ruling on interpreting ambiguous law in an immigration case to support the company's interpretation of law in its $248 million foreign tax credit claim, the federal government told the Tenth Circuit.
Expert Analysis
-
6 Pointers For Attys To Build Trust, Credibility On Social Media
In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.
-
US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.
-
A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
-
SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
-
Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
-
Cayman Islands Off AML Risk Lists, Signaling Robust Controls
As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.
-
The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
-
As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
-
5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
-
The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
-
Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
-
6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
-
Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.