International
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February 14, 2025
Canadian Owes Taxes On Foreign Earnings, Court Rules
A Canadian must pay taxes and penalties on foreign earnings he didn't report to the country's revenue agency from 1998 to 2013, the Tax Court of Canada said in a decision released Friday, rejecting his claim that he was unaware of his reporting obligations.
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February 14, 2025
Australia Releases Thin Capitalization Test Choice Form
The Australian Taxation Office released a form to be used by multinational entities looking to choose between two of the country's new alternative thin capitalization tests, which generally must be done by the time an entity files its tax return for the income year in question.
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February 14, 2025
India Tax Agency Sends Simplification Bill To Parliament
Proposed simplifications to India's income tax code would lop off more than 250,000 words and eliminate over 280 sections in hopes of improving the clarity of the code, among other benefits, an Indian tax agency said.
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February 14, 2025
Trump Tariff Plan Sparks UK Fears Of Retaliation For VAT
The U.K. could be hit with tariffs as part of U.S. President Donald Trump's plan to impose reciprocal measures on countries that levy value-added taxes on American products, with sectors such as pharmaceuticals under threat, experts in Britain warned.
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February 13, 2025
FedEx Avoids Haircut In $85M Tax Credit Fight
The Internal Revenue Service cannot put a haircut on nearly $85 million in tax credits claimed by FedEx for foreign taxes it paid on overseas earnings because statutory law forbids it, a Tennessee federal court ruled Thursday.
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February 13, 2025
Trump Reciprocal Tariff Plan Could Spur Supply 'Nightmares'
The U.S. will explore imposing reciprocal tariffs that equal rates levied by other countries importing American products, President Donald Trump announced Thursday, a move some experts worry will lead to "compliance nightmares" and COVID-level disruptions to supply chains.
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February 13, 2025
Brazil, Spain Push For Global Wealth Tax Standards
The international community must continue to strive toward establishing standards for the taxation of high-net-worth individuals, building on progress made last year, the leaders of Brazil and Spain said Thursday during a conference in Vatican City.
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February 13, 2025
UK Seeking Comments On E-Invoicing Promotion For Biz
The U.K. government is considering standardizing e-invoicing for business transactions to help with the overall promotion of its adoption, HM Revenue & Customs announced Thursday, saying the potential benefits include greater tax accuracy and closing the tax gap.
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February 13, 2025
DOJ Seeks Sanctions Against Widow In FBAR Fight
A widow defending her husband's estate against a $275,000 claim alleging he didn't disclose his Indian bank account to the Internal Revenue Service should be sanctioned for not complying with court-ordered discovery, the U.S. government told a New York federal court.
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February 13, 2025
UK Can't Tax Irish Resident's £8M In Dividends, Court Says
A woman who moved from England to Ireland does not owe U.K. tax on £8 million ($10 million) in dividends she received through shares transferred by her husband, the Court of Appeal ruled Thursday, finding she qualified for an exemption from a residency test.
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February 13, 2025
Italian Gold Smuggler Evaded $27.6M In Taxes, Swiss Say
Swiss authorities filed charges against an Italian citizen they said led a scheme that smuggled gold into Switzerland from Italy that dodged roughly 25 million Swiss francs ($27.6 million) in taxes.
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February 13, 2025
Drilling Contractor Appeals HMRC Win Over £6.7M Tax Bill
A drilling contractor serving offshore oil and gas rigs took its fight against HM Revenue and Customs to the U.K. Supreme Court on Thursday, arguing the tax office was wrong to restrict the company's tax deductions by £6.7 million ($8.4 million).
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February 12, 2025
Ireland Should Broaden Tax Base, OECD Says
Ireland can shore up its medium-term revenue projections by broadening its tax base, the Organization for Economic Cooperation and Development said Wednesday, saying the country's reliance on taxes from multinational entities opens it up to risk.
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February 12, 2025
EU To Consider 3% Digital Tax, Economic Presence Tax
The European Commission plans to look this year at proposals for a blocwide 3% digital services tax, a significant economic presence tax and a framework for income taxation, according to its program of work, signaling its intent to revive past discussions.
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February 12, 2025
Fenwick Brings On IRS Trial Attorney In Seattle
Fenwick & West LLP has added an attorney from the Internal Revenue Service's Office of Chief Counsel to its Seattle office, the firm announced.
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February 12, 2025
Winthrop & Weinstine Brings In Tax Counsel Duo As Co-Chairs
Minneapolis-based Winthrop & Weinstine PA has added tax attorneys from Kirkland & Ellis LLP and Shartsis Friese LLP to become shareholders of the firm and co-chairs of its tax practice, the firm announced Wednesday.
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February 12, 2025
Aussie Greens Party Proposes 10% Tax On Billionaires
The Australian Greens party has proposed a 10% tax on the wealth of the country's 150 billionaires, with projections that the plan would generate AU$50 billion ($31.4 billion) over the next decade to help fund essential services.
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February 12, 2025
Squire Patton Brings On Polsinelli Tax Ace In Houston
Squire Patton Boggs LLP announced Wednesday that a former Polsinelli PC shareholder has joined the tax strategy and benefits practice group in Houston, an addition that helps the firm address growing client needs.
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February 12, 2025
EU Presses Greece To End Tax-Free Shops' Excise Exemption
Greece must remove its excise duty exemption for tax-free shops at borders with non-European Union countries, which has not been allowed under EU regulations since 2017, the European Commission said Wednesday.
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February 12, 2025
Berger Singerman Adds Carlton Fields Tax Pro In Miami
Florida business law firm Berger Singerman has added a new partner to its business, finance and tax team in Miami from Carlton Fields.
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February 12, 2025
EU Parliament Greenlights Changes To Digital VAT Rules
The European Parliament approved a series of changes to the European Union's plans to reform the value-added tax rules of the economic bloc including fully digitalizing VAT reporting, making it harder to dodge the tax in EU jurisdictions, according to a statement Wednesday.
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February 12, 2025
HMRC Can't Tax Canadian Bank For Oil Loan Payments
The U.K. Supreme Court ruled Wednesday that HM Revenue and Customs cannot tax loan payments made to Royal Bank of Canada connected to oil rights in the North Sea because the underlying agreement did not give an oil company the right to work the oilfield.
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February 11, 2025
Trump's Tariffs, GOP Tax Goals Pose Political Puzzle
President Donald Trump's use of wholesale tariffs may generate trillions of dollars across a 10-year budget window, but the economic uncertainty associated with the U.S.'s aggressive trade posture could politically harm Republicans' must-have efforts to shepherd a tax bill into law this year, experts say.
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February 11, 2025
£5.5B Tax Evasion Could Be 'Tip Of Iceberg,' Watchdog Warns
The £5.5 billion ($6.8 billion) annual cost of tax evasion drawn up by HM Revenue and Customs is probably "vastly underestimated" — and the authority has no plan to tackle the gap in the public purse, the government's spending watchdog warned Wednesday.
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February 11, 2025
Ill. Bill Would Trim Corp. Carryover Limit's Time Frame
Illinois would shorten the time frame of a limit on carryover deductions for corporations under the state's income tax law and prohibit the imposition of franchise taxes on domestic or foreign corporations as part of a bill introduced in the state Senate.
Expert Analysis
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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.
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How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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How Law Firms Can Use Account-Based Marketing Strategies
Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.
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Strategic Succession Planning At Law Firms Is Crucial
Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.
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Maximizing Law Firm Profitability In Uncertain Times
As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.
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5th Circ. Ruling Reminds Attys That CBP Can Search Devices
The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.
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Enforcement Of International Tax Reporting Is Heating Up
Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.
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IRS Notice Clarifies R&E Amortization, But Questions Remain
The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.
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Preparing Your Legal Department For Pillar 2 Compliance
Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.
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What Large Language Models Mean For Document Review
Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.
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Participating In Living History Makes Me A Better Lawyer
My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.
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Private Equity Owners Can Remedy Law Firms' Agency Issues
Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.