International

  • May 10, 2024

    Use Of AI For Tax Comment Letters Poses Ethical Quandaries

    While artificial intelligence can streamline the process of conducting a comprehensive review of complex, IRS-proposed federal tax regulations, tax attorneys must be aware of professional and ethical considerations when using it to help draft comment letters to submit to the agency.

  • May 10, 2024

    Australia Looks To Tweak Tax Exemption For US Entertainers

    Australia wants public comments on a proposal that would simplify the elimination of withholding taxes for U.S. entertainers who make $10,000 or less — or the Australian equivalent — in the country in a given year, the Australian Taxation Office said.

  • May 10, 2024

    Calif. OTA In Untested Area On Ruling That Biz Wants Binding

    A decision by California's Office of Tax Appeals that Microsoft can include 100% of the dividends from foreign affiliates in its California sales factor denominator pleased businesses, who now want the OTA to designate the opinion as precedential, thus binding on it and the state Franchise Tax Board.

  • May 10, 2024

    Osborne Clarke Lawyer To Face Tribunal Over Zahawi SLAPP

    An Osborne Clarke LLP partner who represented Nadhim Zahawi could face a disciplinary tribunal over allegations that he used intimidatory warnings in an attempt to silence a critic who was probing the former Conservative chancellor's tax affairs.

  • May 09, 2024

    Mich. Doctor Ordered To Stay In Jail Until Assets Repatriated

    A Michigan doctor fighting accusations that he failed to report his foreign bank accounts will stay in jail, as a federal court declined to release him Thursday when he didn't comply with an order to deposit over $1 million to cover the judgment against him.

  • May 09, 2024

    Pop Star Shakira's €6.6M Spanish Tax Fraud Case Dropped

    A Spanish court dropped a case alleging that Colombian pop superstar Shakira had willfully defrauded the country of €6.6 million ($7.1 million) worth of taxes in 2018, multiple news outlets reported Thursday.

  • May 09, 2024

    Pension Plans Want Witness Stopped In $2B Danish Dispute

    U.S. pension plans accused by Denmark's tax authority of committing $2.1 billion in fraud against the European country by taking illegal refunds on dividends asked a New York federal court to reject the authority's request to depose a witness who pled guilty in Denmark.

  • May 09, 2024

    Voluntary Carbon Credit Trades Will Trigger UK VAT

    Transactions involving voluntary carbon credits in the U.K. will be assessed value-added tax starting in September, HM Revenue & Customs said Thursday.

  • May 09, 2024

    IRS Turning to Final PFIC Rules This Year, Official Says

    The Internal Revenue Service expects to "begin in earnest" this year on final regulations for partnerships that hold stock in passive foreign investment companies, including guidance that would treat partnerships as an aggregate of their partners, an agency official said Thursday.

  • May 09, 2024

    Country Adjustment Would Undermine Common EU Tax Base

    Allowing countries within the European Union to adjust companies' allocated tax base under proposed rules would undermine the rules' goal of streamlining the corporate tax base, according to business groups. 

  • 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."

Expert Analysis

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • 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.

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