International
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October 07, 2025
Senate OKs Top Treasury Atty Pick In Slate Of Confirmations
The Senate approved President Donald Trump's choice of a Sidley Austin LLP partner to be general counsel of the U.S. Department of the Treasury on Tuesday as part of a combined confirmation of 108 nominees to various roles.
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October 07, 2025
German States Vote Against Suspending Global Minimum Tax
A majority of Germany's states voted against a motion to suspend the 15% global minimum tax while the international community is resolving a U.S. proposal to exempt American companies from most of the system, two state finance ministries told Law360 on Tuesday.
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October 07, 2025
Ireland Plans To Revise Laws On Tax Breaks For Interest
Ireland's Finance Department is working on an overhaul to laws covering tax deductions for interest, it announced Tuesday, saying it expects to submit amendments to lawmakers next year that focus on areas like aligning the tax treatment of foreign interest income from trading and passive sources.
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October 07, 2025
IRS Provides Grace Period For Int'l Money Transfer Tax Errors
U.S. financial institutions that handle overseas money transfers won't immediately face penalties if they fail to accurately deposit new excise taxes that are required under the budget reconciliation bill enacted in July, the Internal Revenue Service announced Tuesday.
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October 06, 2025
Fed. Circ. Partially Revives German Steel Co.'s Dumping Suit
The U.S. Commerce Department cannot use a German steelmaker's likely sales prices as a proxy for the cost of producing nonprime steel plates, but the company acted too late to argue for categorizing some plates separately as it challenges Commerce's antidumping investigation, the Federal Circuit said Monday.
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October 06, 2025
IRS Cyber Crime Executive Named Interim Compliance Chief
An Internal Revenue Service criminal investigations executive who founded the division's cyber crimes sections will temporarily take on an elevated role overseeing all agency enforcement operations, the IRS announced Monday.
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October 06, 2025
Italian Police Seize Assets In Suspected €43M Car VAT Fraud
Italian police seized cars, bank accounts, real estate and luxury goods connected to a suspected scheme to evade nearly €43 million ($50 million) in value-added taxes on luxury cars imported from Germany, the European Public Prosecutor's Office said Monday.
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October 06, 2025
London Casino Loses Dispute Over VAT Base Method
HM Revenue & Customs used the correct method for calculating the value-added tax base of a casino, a London court ruled Monday, rejecting the casino's arguments for the use of a special method that would have allowed it to recover more input VAT.
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October 06, 2025
Social Security Chief Adds Duties As Inaugural CEO Of IRS
The current administrator of the Social Security Administration is adding a new role as the Internal Revenue Service's first chief executive officer, Treasury Secretary Scott Bessent announced Monday.
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October 03, 2025
28% Of Large Cos. In Australia Paid No Income Tax Last Year
The share of large companies operating in Australia that paid no income taxes dropped below 30% for the first time during the 2023-2024 period, the Australian Taxation Office said, attributing this to officials curbing tax avoidance.
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October 03, 2025
Indian Gov't Report Floats Fixed Profit Rates For Foreign Cos.
India should revise its permanent establishment rules by introducing an optional scheme to assign fixed profit rates by industry or business model, which would reduce litigation by foreign businesses over profit attribution methods, a government think tank said Friday.
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October 03, 2025
Some Longtime Legal Blogs Go Quiet As Platform Shuts Down
When the online publishing platform Typepad launched more than two decades ago, it became a hub for a then-growing community of law professors and legal bloggers. Its closure this week marked the end of an era that has found some bloggers looking for new homes or opting to call it quits.
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October 03, 2025
DC Circ. Split On Challenge To IRS-ICE Info-Sharing Deal
D.C. Circuit judges seemed split Friday over whether an information-sharing agreement between immigration authorities and the IRS complies with taxpayer privacy protections, with one judge noting during oral arguments that the government immigration arm requesting the tax information appears unauthorized to make the requests.
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October 03, 2025
Getting It Right: An Economist On Transfer Pricing
Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.
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October 03, 2025
Mining Cos. Warn Of OECD Guidance's Transfer Pricing Risks
Mining companies and other stakeholders raised concerns over transfer pricing risks and possible tax disputes arising from proposed guidance on pricing copper exports, according to documents published by the Organization for Economic Cooperation and Development.
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October 03, 2025
Taxation With Representation: Kirkland, Paul Weiss, Cravath
In this week's Taxation With Representation, video game maker Electronic Arts agrees to be acquired by the Saudi Arabia Public Investment Fund, Silver Lake and Affinity Partners; online mortgage giant Rocket closes its acquisition of rival Mr. Cooper Group; and Berkshire Hathaway acquires international energy company Occidental's chemical business.
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October 03, 2025
Denmark's £1.4B Cum-Ex Loss Raises Legal Strategy Doubts
Denmark's "bruising" defeat in its £1.4 billion ($1.9 billion) cum-ex fraud case against trader Sanjay Shah and others calls into question its legal strategy and the scope of its claim, lawyers have said, although they believe an appeal appears inevitable.
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October 03, 2025
Denmark Denied Permission To Appeal £1.4B Cum-Ex Defeat
Denmark cannot revive its £1.4 billion ($1.9 billion) against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.
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October 02, 2025
IRS Data-Sharing Case Won't Be Paused For Gov't Shutdown
The U.S. Department of Justice must still submit court-ordered information in a lawsuit challenging the Internal Revenue Service's sharing of tax data with immigration authorities by Oct. 24, a D.C. federal judge ruled, despite the federal government shutdown that began Wednesday.
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October 02, 2025
German States Push To Halt Min. Tax As US Seeks Exemption
Three German states said they would ask the country's other states Thursday to push the federal government to suspend the 15% global minimum tax in Germany while the U.S. proposal to exempt American companies from most of the system is being resolved.
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October 02, 2025
Debt Recovery Actions Not Taxable Under EU Law, ECJ Says
A holding company pursuing debt recovery is not providing a taxable service to its debtor under European value-added tax law, the European Union's top court ruled Thursday.
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October 02, 2025
Tax KC Sued By Hedge Fund Billionaire Over Negligence
Billionaire Michael Platt and his hedge fund BlueCrest Capital Management have sued a senior One Essex Court barrister who represented them in a dispute with the U.K. tax authority over the identity of awards paid under a special partnership program.
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October 02, 2025
Denmark Loses £1.4B Cum-Ex Fraud Case Against UK Trader
Denmark lost on Thursday its £1.4 billion ($1.9 billion) legal claim against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.
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October 01, 2025
Calif. Importer, Son Both Get Prison For $8M Customs Fraud
A California federal judge sentenced a Los Angeles Fashion District business owner and his son to more than eight years and seven years in prison, respectively, after they were found guilty of ducking more than $8 million in customs duties and failing to report over $17 million in cash transactions on tax returns.
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October 01, 2025
EU Wants To Lead Bloc On UN Tax Treaty's Dispute Section
The European Union's executive branch has asked the bloc's member states to grant it the final say in agreeing to a legally binding protocol on dispute resolution within the United Nations' framework convention on international tax cooperation, saying the matter falls within its responsibilities.
Expert Analysis
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.
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Legal Jeopardy Looms Over Trump's Trade Negotiation Plans
Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.
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What US-India Trade Deal Will Mean For Indian Pharma
Complicated by newly imposed tariffs from the U.S., the outcome of the U.S.-India trade talks is poised to reshape not just trade policy, but also the strategic alignment of the two countries' pharmaceutical ecosystems, says Jashaswi Ghosh at Holon Law Partners.
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Bar Exam Reform Must Expand Beyond A Single Updated Test
Recently released information about the National Conference of Bar Examiners’ new NextGen Uniform Bar Exam highlights why a single test is not ideal for measuring newly licensed lawyers’ competency, demonstrating the need for collaborative development, implementation and reform processes, says Gregory Bordelon at Suffolk University.
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A Simple Way Courts Can Help Attys Avoid AI Hallucinations
As attorneys increasingly rely on generative artificial intelligence for legal research, courts should consider expanding online quality control programs to flag potential hallucinations — permitting counsel to correct mistakes and sparing judges the burden of imposing sanctions, say attorneys at Lankler Siffert & Wohl and Connors.
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The Legal Education Status Quo Is No Longer Tenable
As underscored by the fallout from California’s February bar exam, legal education and licensure are tethered to outdated systems, and the industry must implement several key reforms to remain relevant and responsive to 21st century legal needs, says Matthew Nehmer at The Colleges of Law.
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6 Questions We Should Ask About The Trump Trade Deals
Whenever the text becomes available, certain questions will help determine whether the Trump administration’s trade deals with U.S. trading partners have been crafted to form durable economic relationships, or ephemeral ties likely to break upon interpretive disagreement or a change in political will, says Ted Posner at Baker Botts.
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E-Discovery Quarterly: Rulings On Relevance Redactions
In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.
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Section 1983 Has Promise After End Of Nationwide Injunctions
After the U.S. Supreme Court recently struck down the practice of nationwide injunctions in Trump v. Casa, Section 1983 civil rights suits can provide a better pathway to hold the government accountable — but this will require reforms to qualified immunity, says Marc Levin at the Council on Criminal Justice.