International

  • April 12, 2024

    Co. Suspected Of Laundering AU$1B To Enable Tax Fraud

    Australian authorities seized AU$500,000 ($323,000) from an operation in Sydney suspected of laundering over AU$1 billion to facilitate tax fraud schemes, the authorities announced.

  • April 12, 2024

    4 Arrested In France In €60M VAT Fraud Probe

    European Union prosecutors arrested four people in western France suspected of a €60 million ($63.6 million) value-added fraud scheme involving the transfer of goods and money between several countries inside and outside the bloc, the European Public Prosecutor's Office said Friday.

  • April 12, 2024

    Denmark's £1.4B Tax Fraud Trial Heads For 'Uncharted Waters'

    Denmark will open its £1.4 billion ($1.7 billion) dividend fraud case in London on Monday, beginning a yearlong trial that will have wide implications for other disputes arising out of the cum-ex trading scandal that has swept Europe.

  • April 12, 2024

    Taxation With Representation: Freshfields, Kirkland & Ellis

    In this week's Taxation with Representation, eBay acquires Collectors' Goldin auction house, Vertex Pharmaceuticals buys Alpine Immune Sciences, Vista Equity Partners purchases Model N and Tradeweb Markets buys Institutional Cash Distributors.

  • April 12, 2024

    Countries Late On Pillar 2 Need To Catch Up, EU Official Says

    Countries within the European Union that are late implementing the global minimum tax rules need to do so soon, an official with the European Commission said Friday, adding that countries failing to do so could face fines.

  • April 11, 2024

    BlackRock Can't Deduct Interest On $4B, London Court Finds

    Financial services firm BlackRock cannot deduct interest on $4 billion in loans it used for the 2009 purchase of Barclays Global Investors because avoiding taxes was the main reason for the way it structured the transaction, a London appeals court ruled Thursday.

  • April 11, 2024

    France's Anti-Money Laundering Reports Up 15% In 2023

    France's anti-money laundering unit received 15% more reports of suspicious financial transactions in 2023 compared with 2022, continuing a trend that has resulted in a seven-fold increase in such reports over the past decade, the country's finance ministry said Thursday.

  • April 11, 2024

    Int'l Salesman Stuck With FBAR Fines For Swiss Account

    An agricultural salesman earning money in Ukraine willfully hid a Swiss bank account from the IRS that neither his accountant nor his wife knew about, a Nebraska federal judge said Thursday in upholding more than $600,000 in reporting penalties against him.

  • April 11, 2024

    Tax Controversy Quintet Joins Bradley Arant In Atlanta

    Bradley Arant Boult Cummings LLP announced that it hired a five-person tax controversy team from Chamberlain Hrdlicka White Williams & Aughtry highlighted by the addition of three experienced partners, including two former Internal Revenue Service trial attorneys.

  • April 11, 2024

    Proskauer Adds Kirkland Partner For Tax, Estate Issues

    Proskauer Rose LLP has added to its private client services department a partner from Kirkland & Ellis LLP who specializes in developing domestic and international tax and estate plans for clients with very high net worth, the firm announced.

  • April 11, 2024

    Australia Considering Build-To-Rent Tax Break Increases

    Australia is seeking public input on a plan to increase tax breaks for builders constructing rental properties in the country while also introducing conditions to qualify for those breaks.

  • April 11, 2024

    Swiss Bank Probe May Prompt IRS To Revive Disclosure Effort

    Senate Finance Committee Chairman Ron Wyden's latest investigation into the Swiss banking industry may apply further pressure to federal law enforcement officials to revive a program designed to encourage taxpayers' voluntary compliance in disclosing income held overseas to the IRS.

  • April 11, 2024

    EU Parliament Advances Small Biz Single File Tax Plan

    Small businesses in the European Union would be able to file a single tax return with the administration of the business' head office instead of with every member country where the entity operates under a proposal approved by the European Parliament.

  • April 11, 2024

    Adviser Urges ECJ To Annul Nix Of UK's CFC Tax Breaks

    The European Union's General Court erred by relying on controlled foreign company rules in Great Britain when it found that U.K. corporate tax breaks were illegal, an adviser to the bloc's highest court said Thursday in urging the reversal of that ruling.

  • April 11, 2024

    OECD Plans More Guidance On Global Min. Tax, Official Says

    The Organization for Economic Cooperation and Development will issue further guidance on the global minimum corporate tax, a top official from the organization said Thursday, and another official defended a backstop provision of the minimum tax.

  • April 10, 2024

    Plastic Surgeon Owes $7.7M From Offshore Scheme, US Says

    A now-retired plastic surgeon owes the Internal Revenue Service more than $7.7 million after he ran an offshore employee leasing scheme and he and his wife transferred nearly all their assets to their then-11-year-old daughter, who is now a lawyer, the government told an Ohio federal court.

  • April 10, 2024

    Australia's Tax Office Seeks Input On Risk-Weighted Assets

    The Australian Taxation Office is seeking comments on a paper about how it measures the risk-weighted assets of a foreign bank's Australian branch when applying thin capitalization rules, the ATO announced.

  • April 10, 2024

    EU Parliament Wants Transfer Pricing Rules To Apply Sooner

    The European Parliament voted Wednesday to adopt new transfer pricing rules that would take effect one year earlier than previously planned, sending the proposal to the European Union's council of member countries for consideration.

  • April 10, 2024

    IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says

    The IRS protocols for referring cases to the U.S. Department of Justice are "a disaster" for enforcing laws against bankers and other actors who help U.S. taxpayers evade taxes, Sen. Sheldon Whitehouse said Wednesday during a hearing on offshore tax evasion before the Senate Budget Committee.

  • April 10, 2024

    Belgium's Anticipated Green Tax Break Carries Some Doubts

    A proposal working its way through the Belgian Parliament would create opportunities for investors in green and sustainable technologies, but questions about the long-term durability of the measure, which would offer an expanded deduction for such investments, could weigh on its popularity and effectiveness.

  • April 10, 2024

    EU Gave €46B In State Aid As Tax Breaks In 2022

    European Union countries gave their companies tax breaks worth about €46 billion ($49.4 billion) in state aid in 2022, some to weather the fallout from the Ukraine war and the COVID-19 pandemic and other aid to promote infrastructure projects or environmental protection, a European Commission report said.

  • April 09, 2024

    Treasury Proposes Long-Awaited Stock Buyback Tax Rules

    The U.S. Treasury Department proposed a pair of long-awaited rules Tuesday that detail the calculation and reporting of a new excise tax assessed to publicly traded corporations that recently bought back their own shares of stock on the open market.

  • April 09, 2024

    Healthcare Co. Can't Sue Ex-Exec For Causing Canada Tax Hit

    A Colorado federal judge shot down a pharmacy automation company's suit alleging its former chief commercial officer cost it nearly CA$1.2 million ($907,000) in Canadian taxes by not telling his employer he had moved out of the country, saying the company hasn't shown it suffered any damage as a result.

  • April 09, 2024

    Poland Adopts Digital Platform Reporting Rules

    Poland's Council of Ministers approved a measure Tuesday implementing the European Union's tax information reporting procedures for digital platform operators, known as DAC7, the country's tax authority said.

  • April 09, 2024

    UK Court Affirms Sweet VAT Ruling For Jumbo Marshmallows

    Jumbo-size marshmallows are not candy like regular marshmallows because they're meant to be roasted, so they qualify for a value-added tax exemption for food, the U.K. Upper Tribunal ruled in upholding a lower court's findings.

Expert Analysis

  • 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.

  • Business Litigators Have A Source Of Untapped Fulfillment

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    As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    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

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    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

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    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

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    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

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    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

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    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.

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