International

  • 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.

  • May 21, 2024

    Italy Needs To Adjust Tax Credits To Limit Debt, IMF Says

    While generous Italian tax regimes such as credits for home improvements have helped the country's economy rebound quickly from the pandemic, they also pose a risk to the country's debt burden and need to be adjusted, the International Monetary Fund said.

  • May 21, 2024

    Strategic Hiring Was The New Normal For BigLaw In 2023

    The 400 largest law firms by headcount in the U.S. grew more slowly in 2023 than in the previous two years, while Kirkland & Ellis LLP surpassed the 3,000-attorney threshold, according to the latest Law360 ranking.

  • May 21, 2024

    The Law360 400: Tracking The Largest US Law Firms

    The legal market expanded more tentatively in 2023 than in previous years amid a slowdown in demand for legal services, especially in transactions, an area that has been sluggish but is expected to quicken in the near future.

  • May 21, 2024

    Portuguese Cos. Appeal EU Court Ruling On Tax Breaks

    Three Portuguese companies have appealed a European Union court's judgment backing a European Commission decision that demanded repayment of tax breaks considered to have been illegal, documents published Tuesday showed.

  • May 21, 2024

    EU Adopts Decision To Send Russian Profits To Ukraine

    European Union countries adopted a formal decision Tuesday to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for the war-torn country, a news release said.

  • May 21, 2024

    I Am An Honest Man, British Trader Tells £1.4B Fraud Trial

    Sanjay Shah, a former hedge fund owner who is accused of defrauding Denmark's tax authority out of £1.4 billion ($1.8 billion), told a London court on Tuesday that he is an "honest man" who traded using a legal "loophole."

  • May 21, 2024

    IMF Report Warns UK Against More Tax Cuts

    The United Kingdom should refrain from additional tax cuts unless they are credibly shown to boost economic growth and are offset by measures to cut the deficit, the International Monetary Fund said Tuesday.

  • May 20, 2024

    Transparency Act Violates Constitution, Groups Tell 11th Circ.

    The Corporate Transparency Act's reporting requirements violate the Fifth Amendment's protection against self-incrimination and other constitutional provisions, libertarian think tank Cato Institute and others said Monday in urging the Eleventh Circuit to uphold an Alabama district court's ruling against the law.

  • May 20, 2024

    India's Top Court Says Accounting Body Can Limit Tax Audits

    India's regulatory association for accountants has the authority to limit the amount of tax audits performed by an individual accountant to 60, the Supreme Court of India ruled — even as it canceled ongoing disciplinary proceedings over the restriction because of inconsistent enforcement.

  • May 20, 2024

    IRS Guidance Plan Should Cover Corp. AMT, AICPA Says

    The Internal Revenue Service should provide guidance on the definitions and applications of the 15% corporate alternative minimum tax, among other topics, the American Institute of Certified Public Accountants said in comments published by the agency Monday.

  • May 20, 2024

    Turkey Will Introduce 15% Global Minimum Tax, Minister Says

    The Turkish government will introduce the 15% global minimum corporate tax and will not provide any incentives that would allow companies to pay a lower rate, the country's finance minister told its public broadcaster Monday.

Expert Analysis

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.

  • Judicial Independence Is Imperative This Election Year

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    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.

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