International
-
March 17, 2025
10th Circ. Grapples With Liberty Global's $248M Tax Credit Bid
A Tenth Circuit panel questioned Monday whether Liberty Global is entitled to $248 million in foreign tax credits for the sale of a Japanese affiliate, or if legislation limits the telecommunications giant from classifying the gains as overseas income.
-
March 17, 2025
Kleinberg Kaplan Adds Simpson Thacher Atty As Tax Partner
Kleinberg Kaplan announced Monday that it has added a Simpson Thacher & Bartlett LLP attorney to help provide clients with expertise on tax aspects of private investment fund formation and operation, as well as mergers and acquisitions, joint ventures and financings.
-
March 17, 2025
Coloradan Owes FBAR Penalty After Failing To Appear
An elderly Colorado man who failed to respond to the government's claim that he owed $482,000 for failing to report his foreign bank accounts is on the hook for the bill, a federal court ruled.
-
March 17, 2025
OECD Report Highlights Slow Growth Due To Tariff Impact
The Organization for Economic Cooperation and Development warned Monday that the tariffs between the U.S. and Canada and those between the U.S. and Mexico risk undermining growth at a time when tax revenue is much needed to bring down debt.
-
March 14, 2025
Whistleblower Hasn't Proved Retaliation In Tariff Fraud Case
A former employee of two defunct footwear companies has not shown her boss fired her for confronting him about a scheme she alleged he ran to lower tariffs on certain shoes, a New York federal court ruled, letting her claim that he ran the scheme continue to trial.
-
March 14, 2025
NZ Planning New Method Of Taxing Foreign Investment Funds
New Zealand is proposing a new method for determining taxable income for purposes of taxing investments of 10% or less in foreign companies by certain migrants in hopes of mitigating issues that were discouraging people from moving to the country, its tax agency said Friday.
-
March 14, 2025
Judge Splits $79M Judgment In Danish Tax Fraud Case
A New York federal judge divided a nearly $79 million judgment against four investors and their pension plans after a jury in February found them liable for participating in a tax fraud scheme against the Danish government.
-
March 14, 2025
Ex-Greenberg Traurig Atty Ordered To Pay $15.5M To IRS
A former Greenberg Traurig LLP attorney who was sentenced to prison for helping a musician skirt taxes owes $15.5 million in restitution to the Internal Revenue Service, a New York federal judge ruled.
-
March 14, 2025
Taxation With Representation: Davis Polk, Paul Weiss
In this week's Taxation With Representation, Mallinckrodt PLC and Endo Inc. combine, Rocket Cos. buys Redfin, and Endo divests its international pharmaceuticals business to Knight Therapeutics Inc.
-
March 14, 2025
Struck-Off Lawyer Can't Lift Ban After Misleading HMRC
A former consultant solicitor who misled HM Revenue and Customs to get a refund on stamp duty land tax has failed to have his professional ban lifted as a London court ruled on Friday that the sanction was fair and justified.
-
March 13, 2025
Texan Calls $1.7M In FBAR Penalties Unconstitutional
Constitutional law bars the United States from imposing $1.7 million in penalties for failure to report foreign bank accounts, a Texan said in urging a federal court to dismiss such an assessment against her.
-
March 13, 2025
Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told
The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.
-
March 13, 2025
Australia Clarifying Managed Investment Trust Tax Regime
The Australian government is planning to update its income tax laws to make it clear that trusts ultimately owned by a foreign pension fund can use certain concessional withholding tax rates on eligible distributions to members, the country's assistant treasurer said Thursday.
-
March 13, 2025
Belgian Firm Can Nix Dividends From Tax Base, Court Rules
A Belgian engineering company was entitled to reduce its tax base by excluding dividends from its subsidiaries in member states before taxation, as per EU law and contrary to Belgian law, the Court of Justice of the European Union said in a preliminary ruling Thursday.
-
March 13, 2025
Former IRS Counsel Joins Hinshaw In Chicago
Hinshaw & Culbertson LLP announced that a longtime government attorney who most recently served as deputy managing counsel of the Internal Revenue Service Office of Chief Counsel in Chicago, has joined the firm's government practice as a partner.
-
March 13, 2025
Akin's Energy Transition Group Grows With V&E Tax Atty
Akin Gump Strauss Hauer & Feld LLP has hired a Vinson & Elkins LLP tax counsel who has spent the past decade counseling clients on the federal income tax aspects of energy transition transactions, the firm announced Thursday.
-
March 13, 2025
5th Circ. Asks If Enforcement Delay Affects CTA Challenge
The Fifth Circuit has asked for supplemental briefing in a challenge against the Corporate Transparency Act, asking whether the case is affected by the U.S. Treasury Department's recent decision to suspend enforcement of reporting rules for domestic companies.
-
March 13, 2025
Trump's EU Threat May Aim To Boost Negotiation Leverage
President Donald Trump continued his trade tactics Thursday, threatening a 200% tariff on European alcohol imports that is almost certain to be another tool to leverage in future negotiations despite the economic uncertainty it creates.
-
March 13, 2025
Funding Deficiency May Hinder UN Tax Talks, Group Says
Governments interested in pursuing a United Nations tax convention should step up funding for the organization, which is facing a budget shortfall, according to the Tax Justice Network, as U.S. arrears drag on quicker-than-usual funding from other countries.
-
March 13, 2025
Insurance Brokers Could Get Tax Refunds After Court Ruling
U.K. insurance brokers could be in line for tax refunds from the state worth up to £400 million ($518 million) after a landmark court case, according to accountancy MHA.
-
March 13, 2025
Wait To File Taxes If You Have Capital Gains, Canada Says
The Canada Revenue Agency recommended that taxpayers with capital gains wait to file their tax returns as it finalizes updates to its system to account for the delayed proposed increase in the inclusion rate, saying it will waive late-filing penalties.
-
March 12, 2025
OECD Calls On Costa Rica To Limit Regressive Exemptions
Costa Rica's tax revenue makes up just 25% of the country's gross domestic product, thanks in part to regressive exemptions to value-added and personal income taxes and its overall narrow tax bases, the Organization for Economic Cooperation and Development said.
-
March 12, 2025
Judge Tosses Tax Fraud Claim In Mariana Bribery Case
A federal court dismissed Wednesday a claim connected to allegations of tax fraud in a $310,000 civil asset forfeiture case brought by the U.S. government against a Northern Mariana Islands business after concluding the court lacked jurisdiction.
-
March 12, 2025
Starbucks' Sourcing Aided $1.3B Low-Tax Profits, Report Says
Starbucks leveraged its private certification program for coffee growers to boost profits transferred almost tax-free from Switzerland to the Netherlands to the U.K., amounting to an estimated $1.3 billion between 2011 and 2021, according to a report from a union-funded nonprofit organization.
-
March 12, 2025
Tariffs Prompt Chipmakers To Look At Manufacturing Moves
The U.S. semiconductor industry is considering moving manufacturing operations to the U.S. and elsewhere as a tariff-mitigation strategy with President Donald Trump threatening to levy the sector and its supply chains, professionals told Law360.
Expert Analysis
-
How To Clean Up Your Generative AI-Produced Legal Drafts
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
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
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
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
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
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
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
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.
-
Firms Must Rethink How They Train New Lawyers In AI Age
As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.
-
Think Like A Lawyer: Always Be Closing
When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.
-
Litigation Inspiration: Attys Can Be Heroic Like Olympians
Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.
-
Lean Into The 'Great Restoration' To Retain Legal Talent
As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.
-
Fishing Makes Me A Better Lawyer
Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge at Robinson Bradshaw.