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May 09, 2026
Admin Cost Of Tax Presence Shouldn't Top Profit, Pros Say
The administrative costs for a company or individual triggering a taxable presence, or permanent establishment, in a jurisdiction shouldn't exceed the profit allocable to the entity, transfer pricing specialists said Friday.
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May 08, 2026
AI's Use In Transfer Pricing Still Evolving, Tax Pros Say
The use of artificial intelligence in transfer pricing is expected to ease compliance and reduce costs for clients, but multiple questions remain about the technology's potential and how it should be applied, a panel of tax experts said Friday.
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May 08, 2026
Disbarred Atty Can't Escape Tax Evasion Case, 2nd Circ. Says
A disbarred English attorney who assisted the heirs of an American businessman in evading taxation on their inheritance cannot use an "extraordinary" post-conviction remedy to overturn part of the verdict and a $4 million restitution bill, the Second Circuit ruled Friday.
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May 08, 2026
Nike Customers Join Tariff Refund Class Action Trend
A group of Nike customers on Friday joined the growing number of proposed class actions looking to secure legal rights to refunds of costs tied to President Donald Trump's now-invalidated global tariff regime, saying they were the ones who actually bore the costs.
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May 08, 2026
Clarity Sought On Energy Tax Credits And Foreign Debt
The IRS should issue more guidance on what kind of debt arrangements can limit a development project's access to clean energy tax credits under new prohibited foreign entity requirements as uncertainty over financial liability and ownership becomes a major market concern, practitioners said Friday.
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May 08, 2026
US, Romania Have Wrapped Up Tax Treaty Talks, Official Says
The U.S. and Romania recently completed negotiations on their double-tax treaty and are conducting reviews of the changes, an official with the U.S. Department of the Treasury said Friday.
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May 08, 2026
Former Exec Didn't Prove Resignation, Canada Tax Court Says
A businessman didn't exercise due diligence and failed to prove he stepped down from a company position, leaving him liable for unremitted goods and services taxes, a Toronto court ruled.
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May 08, 2026
Taxation With Representation: Corrs, Kirkland, Linklaters
In this week's Taxation With Representation, gold companies Regis Resources and Vault Minerals combine, Long Lake Management acquires American Express Global Business Travel and Vodafone buys out CK Hutchison Holdings to become the sole owner of their telecommunications joint venture.
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May 08, 2026
UK Dentist Wins Appeal To Overturn £225K In Tax Penalties
A London tribunal canceled tax penalties totaling nearly £225,000 ($306,000) that Britain's tax authority imposed on a dentist who unwittingly joined a fraudulent tax scheme on the advice of his accountant.
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May 08, 2026
Liberty Global Easy Case For 10th Circ., IRS Atty Says
The Internal Revenue Service's recent win against telecommunications giant Liberty Global, whose complex transactions were held to be a tax shelter lacking economic substance, was an "easy affirmance" for the Tenth Circuit and an easy decision for the district court, an agency official said Friday.
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May 07, 2026
Wyden Probes Wall Street Firms For Tariff Refund Stakes' Info
The top Democratic lawmakers on the Senate Finance Committee sent letters to major Wall Street firms Thursday about their activity in buying the rights to importers' tariff refund interests at a discount following the U.S. Supreme Court's decision in February striking down President Donald Trump's emergency tariff regime.
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May 07, 2026
Carbon Tax Revenues Fall Far Short Of Potential, Report Says
Carbon taxes worldwide raised less than a third of the revenue they could have recently, weighed down by exemptions, reduced rates, compliance gaps and other carbon pricing systems carving out the tax base, the Tax Foundation said Thursday in a report.
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May 07, 2026
Stinson Real Estate Finance Atty Joins Reed Smith In DC
Reed Smith LLP has hired a Stinson LLP lawyer who focuses her practice on real estate finance matters, renewable energy tax credit and new market tax credit issues, the firm has announced.
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May 07, 2026
Italian Man Arrested Amid Probe Into Large-Scale VAT Fraud
Italian authorities have arrested a businessman suspected of laundering the proceeds of a multimillion-euro value-added tax fraud, the European Public Prosecutor's Office said.
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May 07, 2026
Iran War Sees Germany Downgrade Tax Revenue Expectations
Germany downgraded its tax revenue forecasts Thursday at all levels of government for each year through 2030 due to the Iran war.
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May 06, 2026
Sony Reaped 'Windfall' From Illegal Tariffs, Gamers Say
Sony Interactive Entertainment LLC retained a "substantial windfall" generated by illegal tariffs imposed under the International Emergency Economic Powers Act, two Sony PlayStation console owners said Wednesday in a proposed class action in California federal court.
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May 06, 2026
Swedish Tax Agency Can Deny Input VAT Credits Under Audit
The Swedish Tax Agency will be able to deny credits for significant amounts of excess input value-added taxes during audits under a bill adopted Wednesday by lawmakers.
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May 06, 2026
IRS Gets Protest Of Wedding Gift Penalties Narrowed
A Chinese citizen seeking a refund of penalties imposed by the IRS over a failure to report wedding gifts she received from abroad cannot argue the agency must collect the penalties through a civil action, a California federal court said, partially dismissing her suit.
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May 06, 2026
Insurers Ask To Ignore Simplified Foreign Currency Rules
The insurance industry should be allowed to ignore regulations from 2024 covering how corporations determine taxable income with respect to affiliates that conduct business in a foreign currency, the American Council of Life Insurers told the U.S. Treasury in a letter released Wednesday.
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May 06, 2026
HMRC To Increase Electricity Generator Windfall Tax
Britain's tax authority set out plans to increase the rate of the windfall tax from 45% to 55% on electricity generators charging above the benchmark price in July as part of government efforts to keep prices down, according to a policy paper published Wednesday.
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May 05, 2026
Ending Carried Interest Tax Break May Net $88B, Report Says
Ending the carried interest tax break could raise far more than previously estimated, nearly $88 billion in a decade, based on a new methodology put forward in a report by the Yale Budget Lab.
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May 05, 2026
Portugal Aims To Tax Windfall Energy Profits, Report Says
The Portuguese government will propose a windfall tax on energy companies and potentially on large retail chains, the country's finance minister said Tuesday, according to a report by a state-owned public broadcaster.
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May 05, 2026
Calif. OTA Says Dutch Consultant Must Pay State Tax
A consultant residing in the Netherlands owes California income tax for work he did on projects in the state, the California Office of Tax Appeals ruled, saying U.S. tax treaties with his country do not shield him from state taxation.
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May 05, 2026
Tribunal Hands Referee Co. Win In £584K Tax Status Case
An English soccer referee body won its decadelong dispute with the U.K.'s tax authority after a London tribunal ruled that referees' match-day engagements were contracts for services rather than employment, meaning the group isn't liable for the referees' taxes.
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May 05, 2026
Tax Reform Crucial To EU-Ukraine Loan Talks, Official Says
A European Union official said Tuesday that tax reform is an important part of negotiations with Ukraine over unlocking a portion of a €90 billion ($105.3 billion) financial assistance loan for the country.
Why Trump's 2nd Global Tariff May Fare Better On Appeal
President Donald Trump's administration on Friday appealed the U.S. Court of International Trade's ruling deeming his temporary global tariff unlawful to the Federal Circuit, where judges may view the executive action with more deference than the measures it immediately replaced.
Trump's Temporary Global Tariffs Illegal, Trade Court Rules
President Donald Trump's temporary global 10% tariffs are unlawful because the narrow set of economic conditions required for the measure to be imposed were not met, the U.S. Court of International Trade said Thursday in a divided opinion.
Iran War Risks £8B Annual Tax Hit To UK, Report Warns
The Iran war could cost the U.K. government up to £8 billion ($10.9 billion) a year through lost tax revenue and higher debt interest payments, a progressive think tank warned Thursday.
Featured Stories
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Push To Juice German Economy Could Jolt Spousal Tax Break
With growth fragile and unemployment high, Germany's coalition government is considering a raft of tax changes intended to boost workforce participation, including a proposal by the center-left Social Democratic Party to change the country's spousal tax-splitting system.
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Int'l Tax In April: Progress On Tariff Refunds, New Tax Cuts
U.S. Customs and Border Protection continued to make progress in April on its system for paying back the tariffs that President Donald Trump imposed under the International Emergency Economic Powers Act. Meanwhile, several countries and one U.S. state cut fuel taxes in response to the U.S. and Israel's war with Iran. Here, Law360 looks at those and other international tax developments from the past month.
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One Certainty As Tariff Refunds Start: 'There Will Be Litigation'
The launch of the refund process for tariffs struck down by the U.S. Supreme Court marks the start of lengthy and multifaceted court battles as companies fight with consumers — and amongst themselves — about who gets a slice of the $166 billion pie, experts told Law360.
Expert Analysis
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Speed Jigsaw Puzzling Makes Me A Better Lawyer
My passion for speed puzzling — I can complete a 500-piece jigsaw puzzle in under 50 minutes — has sharpened my legal skills in more ways than one, with both disciplines requiring patience, precision and the ability to keep the bigger picture in mind while working through the details, says Tazia Statucki at Proskauer.
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Documenting Business Purpose After IRS' 10th Circ. Win
Following the Tenth Circuit’s recent Liberty Global v. U.S. decision, which held the economic substance doctrine does not require a threshold relevancy determination, taxpayers can prepare for potential audits by maintaining contemporaneous documentation and taking other steps that demonstrate the business purpose of transactions, say attorneys at Crowell & Moring.
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2 AI Snafus Show Why Attys Can't Outsource Judgment
The recent incident involving Sullivan & Cromwell where citations in a filed motion were fabricated by artificial intelligence, as well as a punitive ruling from the Sixth Circuit in U.S. v. Farris, demonstrate that the obligation to supervise AI has belonged and always will belong to lawyers, says John Powell at the Kentucky School Boards Association.
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Improving Well-Being In Law, 10 Years After Landmark Study
An important 2016 study revealed significant substance abuse and mental health issues among lawyers, and while the findings helped normalize the conversation around these topics, a decade later, structural change is still needed, says Denise Robinson at PLI.
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Hungary CPAC Funding Probe Could Implicate US Entities
A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political and financial dimensions that create multiple touchpoints for U.S. regulatory and enforcement interest, say attorneys at Ballard Spahr.
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Mitigating Multistate Risks As California Expands Tax Reach
Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain other steps to protect clients from the costs of losing a future audit, says attorney Delina Yasmeh.
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E-Discovery Quarterly: Recent Rulings On ESI Control
Several recent federal court decisions have perpetuated a split over what constitutes “control” of electronically stored information — with judges divided on whether the standard should turn on a party's legal right or practical ability to obtain the information, say attorneys at Sidley.
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2 Discovery Rulings Break With Heppner On AI Privilege Issue
While a New York federal court’s recent ruling in U.S. v. Heppner suggests that some litigants’ communications with AI tools are discoverable, two other recent federal court decisions demonstrate that such interactions generally qualify for work-product protection under the Federal Rules of Civil Procedure, says Joshua Dunn at Brown Rudnick.
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CBP's $166B Tariff Refund Portal Needs 4 Safeguards
Before launching its automated web portal to process tariff-refund disbursements on April 20, U.S. Customs and Border Protection should apply the expensive lessons learned from the pandemic-era employee retention credit, says Peter Gariepy at RubinBrown.
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Calculating Damages In IEEPA Tariff Refund Litigation
To calculate damages in the spate of refund litigation triggered by the U.S. Supreme Court's recent decision invalidating tariffs collected under the International Emergency Economic Powers Act, the central question will be how to determine where in the supply chain their economic burden ultimately came to rest, say analysts at Charles River Associates.
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Alpine Skiing Makes Me A Better Lawyer
Skiing has shaped habits I rely on daily as an attorney — focus, resilience and the ability to remain steady when circumstances shift rapidly — and influences the way I approach legal strategy, client counseling and teamwork, says Isaku Begert at Marshall Gerstein.
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What A Court Doc Audit Reveals About Erroneous Filings
My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.
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Getting The Most Out Of Learning And Development Programs
Excerpt from Practical Guidance
Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.