International

  • 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

    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.

  • May 20, 2024

    Isle Of Man Commits To Portion Of Global Minimum Tax

    The Isle of Man plans to introduce legislation implementing the qualified domestic minimum top-up tax portion of the OECD's Pillar Two directive starting in 2025 but is less committed to adopting the income inclusion rule, the island's Treasury said Monday.

  • May 20, 2024

    HMRC Lays Out Registration Rules For Pillar 2

    Companies covered by the U.K.'s implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax directive must register with HM Revenue & Customs within six months of the accounting period that makes them eligible, the agency said Monday.

  • May 20, 2024

    US, Argentina To Carry Out 1st FATCA Info Exchange

    The Internal Revenue Service approved cybersecurity measures by Argentina in a step that clears the way for the first automatic information exchange under the Foreign Account Tax Compliance Act between the two countries in September, Argentina's revenue service said Monday.

  • May 17, 2024

    Michigan Doctor Seeks Release From Contempt In FBAR Fight

    A Michigan doctor incarcerated for civil contempt in a case in which he was ordered to repay more than $1 million in penalties for failure to report foreign accounts should be freed because he can no longer satisfy the terms of his release, he told a Michigan federal court.

  • May 17, 2024

    Koch-Tied Group Says Transparency Law Offends Federalism

    The Corporate Transparency Act is unconstitutional because it does not regulate interstate commerce yet mandates that state-registered entities disclose personal information, a conservative group affiliated with the billionaire Koch brothers told the Eleventh Circuit on Friday.

  • May 17, 2024

    Credit Suisse Can't Reverse $21.3M Biz Loss Denial

    Credit Suisse cannot carry forward $21.3 million in business losses from 2015-2017 to its 2018 Michigan tax return, a state appeals court said, letting stand a ruling that the bank miscalculated its business income from those years on its returns.

  • May 17, 2024

    New Domestic Content Guidance May Boost Energy Credits

    The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.

  • May 17, 2024

    Italian Financial Police Uncover €1B Tax Credit Scam

    The Italian Financial Police placed more than 300 people under investigation after uncovering a scheme to collect more than €1 billion ($1.09 billion) in tax credits designed to promote construction and energy matters, authorities said.

  • May 17, 2024

    Transfer Pricing Deal Needed For Pillar 1, OECD Official Says

    It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.

  • May 17, 2024

    New Dutch Gov't Outlines Range Of Tax Measures

    The incoming Dutch government has outlined numerous tax measures affecting companies and individuals in its preliminary coalition agreement, a government document showed.

  • May 17, 2024

    UK, Peru Agree To Double-Tax Treaty

    The U.K. and Peru reached a deal on a treaty to prevent double taxation after several years of discussion, the countries said Friday.

Featured Stories

  • Nixing Green Energy Tax Perks Would Be Tough For Trump

    Kat Lucero

    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.

  • New Domestic Content Guidance May Boost Energy Credits

    Kat Lucero

    The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.

  • 3 Key Takeaways From Floated Foreign Trust Reporting Rules

    Natalie Olivo

    Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.

Expert Analysis

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

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    Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • 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.