International

  • May 08, 2024

    DOJ Says Man Owes $6.2M After Failing To Report Foreign Biz

    A man owes tax penalties of $6.2 million to the U.S. after failing to disclose his ownership interests in two foreign entities from 1997 to 2004, the government told a California federal court Wednesday.

  • May 08, 2024

    Biz Groups Tell 10th Circ. Economic Substance Doesn't Apply

    The economic substance doctrine doesn't apply when a business considers tax in making a choice between two legally permissible alternatives, two organizations told the Tenth Circuit in their briefs supporting Liberty Global's position in its $109 million tax refund bid.

  • May 08, 2024

    4th Circ. Asks If High Court Ruling Bars Credit Suisse Tipster

    A Fourth Circuit panel questioned Wednesday whether a U.S. Supreme Court ruling prevented it from reviving a whistleblower case by a former Credit Suisse employee alleging the bank helped U.S. citizens evade taxes after paying a $2.6 billion criminal penalty.

  • May 08, 2024

    Auto Cos. Brace For EV Battery Compliance Hurdles

    New federal regulations aimed at shoring up the domestic electric vehicle manufacturing supply chain give automakers a much-needed two-year cushion to navigate a compliance minefield, and to figure out how to reinvigorate the recent waning consumer demand for electric vehicles.

  • May 08, 2024

    Africa Should Solve Own Tax Problems, Nigerian Official Says

    The solutions to Africa's taxation challenges should come from those actually on the continent, not the Western world, the chairman of Nigeria's tax authority said at an African Tax Administration Forum meeting, the authority said Wednesday.

  • May 08, 2024

    EGC Won't Annul EU Decision To Toss Spanish Tax Scheme

    The European General Court will not annul a European Commission decision that a Spanish tax scheme for vessels built in its domestic shipyards must be abandoned because it was incompatible with the European Union's internal market, according to a judgment released Wednesday.

  • May 08, 2024

    Ambulance Co.'s Former Owner Gets 6 Years For Tax Evasion

    The former owner of an ambulance company was sentenced to more than six years in federal prison for failing to pay employment taxes to the federal government and obstructing the Internal Revenue Service as it tried to collect, according to Virginia federal court documents.

  • May 08, 2024

    A Foley Hoag Co-Chair Joins Litigation Firm As Name Partner

    Litigation and dispute resolution firm Elliott Kwok Levine & Jaroslaw LLP will operate under a new name after welcoming as its newest name partner a former federal prosecutor who most recently co-chaired Foley Hoag LLP's white-collar crime and government investigations practice.

  • May 08, 2024

    UN To Publish Draft Terms Of Reference For Tax Pact In June

    National governments agreed Wednesday to publish the first draft of terms of reference for the United Nations Framework Convention on International Tax Cooperation for a two-week consultation during the week beginning June 3.

  • May 08, 2024

    EU Races To Deals On Withholding Tax, Digital VAT

    European Union countries are trying to clear the final hurdles for deals on May 14 regarding a withholding tax refund law and a package to modernize value-added tax reporting, although some potential vetoes remain after a preparatory meeting, EU sources said Wednesday.

  • May 08, 2024

    Offshore Drilling Co. Demands $70M Refund From IRS

    The IRS wrongfully withheld $69.7 million in tax refunds to an offshore drilling company, despite acknowledging that the refunds are justified by net operating loss carrybacks authorized by a pandemic law and then promising to pay, the company said in Texas federal court.

  • May 08, 2024

    EU Agrees To Send Russian Assets' Revenue To Ukraine

    European Union countries reached a deal Wednesday to transfer the net income from frozen and immobilized Russian state assets to EU funds for rebuilding Ukraine and buying arms for the country, an EU commissioner said.

  • May 08, 2024

    EU Discusses Monitoring Measures Against Tax Havens

    The European Union is considering an annual monitoring process over defensive measures against tax havens in force in the 27 bloc countries, an EU official said Wednesday.

  • May 08, 2024

    Slow Tax Decisions By EU States Are Harmful, Lawmaker Says

    The slow pace of European Union countries in reaching decisions on tax issues harms the bloc's economy, a conservative member of the European Parliament said in a document sent to journalists Wednesday.

  • May 08, 2024

    EU Calls For Responses On Information Exchange Law

    The European Union's executive branch is seeking responses on the law that governs the exchange of information between tax authorities in the group of 27 nations, as a senior EU tax official said it was time to "assess the need for fine tuning."

  • May 07, 2024

    Biz Orgs. Ask 10th Circ. To Toss Economic Substance Ruling

    The Tenth Circuit must not uphold a Colorado federal court's ruling that it didn't need to determine whether economic substance doctrine was relevant before disallowing an intercompany transaction by Liberty Global Inc., three business groups told the Tenth Circuit in briefs Tuesday.

  • May 07, 2024

    India's Top Court Upholds Tax On Employee Perks

    A catch-all provision in India's tax on employee perks does not grant excessive power to the tax authority, and the tax rate on interest-free loans as perks is not unconstitutional, the Supreme Court of India affirmed Tuesday.

  • May 07, 2024

    Industry Groups Suggest Changes To Aussie Reporting Rules

    A coalition of global fund industry associations asked Australia to further amend its proposal for public country-by-country tax data reporting by including, among other measures, a provision that would allow companies to withhold sensitive information, according to a letter released Tuesday by the U.S. Treasury Department.

  • May 07, 2024

    India High Court Says Biz's Tax Refunds Can't Be Held Back

    Indian tax authorities must refund value-added taxes of 225 million rupees ($2.7 million) to a business instead of withholding them to offset future tax liabilities, the country's top court ruled.

  • May 07, 2024

    Latin American, Caribbean 2022 Tax Revenue Up, OECD Says

    Tax revenue in Latin American and Caribbean countries rose in 2022, thanks in large part to gains in the gas and oil sector, but the average tax-to-gross domestic product ratio in the region still lags behind the OECD average, the organization said Tuesday.

  • May 07, 2024

    14 Arrested In €15M VAT Fraud Ring Tied To Lubricating Oil

    Authorities arrested 14 people as part of an investigation into a crime ring that evaded more than €15 million ($16.1 million) in value-added taxes and other levies tied to lubricating oil, the European Public Prosecutor's Office said Tuesday.

  • May 07, 2024

    EU Pauses Drive For Deal On Energy Tax

    The chair of European Union finance ministers gave up attempts to reach an agreement on a landmark energy taxation law because of sharply diverging views among EU countries, a source from Belgium's EU presidency confirmed Tuesday.

  • May 07, 2024

    Austrian Finance Chief Backs Tax Breaks For Full-Time Work

    Austria's finance minister said he backed proposals to use the tax system to encourage individuals to work full time, including freeing overtime work from taxation.

  • May 07, 2024

    Treasury Floats Foreign Trust Reporting Rules

    The U.S. Treasury Department proposed regulations Tuesday that provide guidance on the requirements for individuals to report their transactions with foreign trusts to the Internal Revenue Service, including the receipt of large gifts.

  • May 06, 2024

    10th Circ. Urged To Alter Substance Finding In Liberty Global

    To preserve the stability of federal tax law, the Tenth Circuit should reverse a lower court's finding that it needn't determine the economic substance doctrine is relevant before disallowing a transaction's tax benefits, the National Foreign Trade Council said Monday, supporting telecommunications firm Liberty Global.

Expert Analysis

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • 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.

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