• July 17, 2024

    Labour Gov't To Make Fiscal Rules Law, Empower OBR

    The new Labour government will legislate to write into law the Treasury's long-held fiscal rules and grant new powers to the Office for Budget Responsibility to scrutinize policy, according to plans confirmed in the King's Speech on Wednesday.

  • July 16, 2024

    Intracompany Prices Should Reflect Acquired IP, Panelists Say

    When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.

  • July 16, 2024

    More Geographic Adjustments 'On The Table' For Amount B

    Countries' ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD's plan for reallocating taxing rights among jurisdictions — is "still on the table," an official from the organization said Tuesday.

  • July 16, 2024

    Va. Tax Head Nixes Assessment On Man For Work In India

    A Virginia man was wrongly assessed income tax for services he conducted while living in India, the state's tax commissioner said in a letter ruling published Tuesday.

  • July 16, 2024

    Tax Transparency Neglected In Latin America, Ex-Officials Say

    The international tax transparency system is failing to produce results for Latin American governments, whose scant information requests are too often met with resistance and whose prosecutions generally lack a cross-cutting approach to tax, former officials from the region said Tuesday.

  • July 16, 2024

    DC Circ. Upholds Dismissal Of Tax Whistleblower Award Case

    The D.C. Circuit upheld Tuesday the U.S. Tax Court's dismissal of a Mississippi man's case seeking review of the denial of his whistleblower claim for 30% of the revenue collected by an Internal Revenue Service offshore voluntary disclosure program.

  • July 16, 2024

    EU Opposed Fast-Tracking Reforms Under UN Tax Convention

    The European Union is concerned that a majority of countries want to create early protocols simultaneously with a United Nations framework convention on international tax cooperation, according to a statement endorsed Tuesday by the bloc's finance ministers.

  • July 16, 2024

    Australian Tax Pros Push Back On Updated Code Of Conduct

    Ten groups representing tax professionals in Australia said the government should reconsider newly passed changes to the country's code of conduct for tax agent services, saying the rules have created inconsistencies and uncertainties.

  • July 16, 2024

    Rising Star: Skadden's Melinda Gammello

    Melinda Gammello of Skadden Arps Slate Meagher & Flom LLP has advised numerous clients before the U.S. Tax Court and elsewhere on complex tax matters, including transfer pricing issues and the treatment of financial transactions within a company, earning her a spot among the tax law practitioners under 40 honored by Law360 as Rising Stars.

  • July 16, 2024

    The 2024 Diversity Snapshot: What You Need To Know

    Law firms' ongoing initiatives to address diversity challenges have driven another year of progress, with the representation of minority attorneys continuing to improve across the board, albeit at a slower pace than in previous years. Here's our data dive into minority representation at law firms in 2023.

  • July 16, 2024

    These Firms Have The Most Diverse Equity Partnerships

    Law360’s law firm survey shows that firms' efforts to diversify their equity partner ranks are lagging. But some have embraced a broader talent pool at the equity partner level. Here are the ones that stood out.

  • July 16, 2024

    Turkish Parliament Considering Global Minimum Tax

    Turkey's Parliament is considering implementing the Organization for Economic Cooperation and Development's 15% global minimum tax on some large multinational corporations alongside other tax changes, according to news reports Tuesday.

  • July 16, 2024

    Labour Government Urged To Introduce Green Tax Credits

    The new Labour government should introduce tax credits for businesses investing in green energy technology, according to a tax expert from the Confederation of British Industry.

  • July 16, 2024

    EU Leader Stresses Importance Of Digital VAT Law

    The head of the European Union's council of members stressed on Tuesday the importance of an agreement on a change to EU VAT law that was blocked by one member country in consecutive meetings in May and June.

  • July 16, 2024

    Top UK Court Rules Deal Advice Fees Are Not Tax Deductible

    Britain's Supreme Court ruled Tuesday that £2.5 million ($3.2 million) paid in advisory fees by an investment company to Deutsche Bank and others is not tax-deductible as the expenses were "capital in nature" spent trying to dispose of a Dutch business.

  • July 15, 2024

    CarMax Distorted SC Activity To Lower Taxes, Judge Says

    CarMax Auto Superstores Inc. used intercompany transactions to distort an entity's business activity and thus its tax burden in South Carolina, an administrative law judge ruled, finding the company should have used an alternative apportionment method to properly calculate income.

  • July 15, 2024

    Distributions Were Not Dividends, Canada Tax Court Says

    Distributions to shareholders after the sale of a Canadian video game company were properly taxed as employee benefits instead of dividends, the Tax Court of Canada ruled.

  • July 15, 2024

    Israeli Firm Seeks To Amend Suit Against GILTI Regs

    The owner of an Israeli law firm asked a D.C. federal court to let him amend his challenge to regulations for the U.S. tax on global intangible low-taxed income after the D.C. Circuit determined parts of his arguments went unconsidered.

  • July 15, 2024

    Former Doctor Seeks Jail Release In FBAR Fight

    An incarcerated former doctor asked a Michigan federal court Monday to lift its order of civil contempt for his failure to pay about $1 million in foreign account reporting penalties, saying he has done all he can to repatriate offshore securities.

  • July 15, 2024

    Widow To Pull $1.7M From Swiss Bank To Pay FBAR Penalties

    A logger's widow agreed to pull about $1.7 million from her Swiss bank account to pay down penalties that her late husband's estate owes the IRS for his failure to report offshore accounts, according to a filing Monday in a Colorado federal court.

  • July 15, 2024

    AICPA Suggests Revising Foreign Trust Loan Anti-Abuse Rule

    The U.S. Treasury Department should scrap or revise significantly an anti-abuse rule for nonresident aliens who receive loans from foreign trusts, which was included in proposed regulations on how to report foreign trust transactions, the American Institute of Certified Public Accountants said in a letter published Monday.

  • July 15, 2024

    Aussie Hydrogen Tax Credit Should Be Doubled, Group Says

    Australia's proposed hydrogen production tax incentive, which would allow eligible projects to claim a credit worth AU$2 ($1.35) per kilogram of renewable hydrogen, should be doubled, a business group said in a set of recommendations on the plan.

  • July 15, 2024

    Akerman Brings On Chamberlain Hrdlicka Tax Pros In Atlanta

    Akerman LLP announced Monday that it picked up a pair of new partners for its tax practice group in Atlanta who were previously with Chamberlain Hrdlicka White Williams & Aughtry.

  • July 15, 2024

    3 Arrested In German Probes Of €8.6M VAT Fraud Rings

    Three suspects have been arrested in German-led investigations of two fraud rings involving the security and surveillance industry that evaded a total of €8.6 million ($9.4 million) in value-added taxes, Hamburg's tax authority announced Monday.

  • July 15, 2024

    Bermuda Proposes New Agency For Corp. Taxation

    Bermuda's Legislature will consider a proposal to establish a Corporate Income Tax Agency to administer the island nation's corporate income tax regime, including its recently enacted 15% global corporate minimum tax on large multinational corporations.

Featured Stories

  • 3 Tax Reg Groups That May Be Shaky After High Court Rulings

    Natalie Olivo

    The U.S. Supreme Court issued two rulings that, when combined, open up long-standing federal regulations to challenges without judicial deference to agencies — a pairing that could weaken several categories of tax rules, including guidance issued under the 2017 federal overhaul. Here, Law360 looks at three batches of tax regulations that may be vulnerable in the aftermath of the high court's decisions.

  • French Left's Tax Pledges May Go Unfulfilled

    Todd Buell

    The tax policy pledges put forward by the leftist bloc of parties that won the most seats in France's legislative election may not be fulfilled given the bloc's failure to win an outright majority.

  • Top International Tax Cases Of 2024: Midyear Report

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    With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.

Expert Analysis

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.

  • Atty Well-Being Efforts Ignore Root Causes Of The Problem

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    The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.

  • Unpacking The Circuit Split Over A Federal Atty Fee Rule

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    Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.

  • After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1

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    The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.

  • Recruitment Trends In Emerging Law Firm Frontiers

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    BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.