International
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September 26, 2025
Microsemi, IRS Reach Deal To Settle Transfer Pricing Dispute
The Internal Revenue Service has reached a settlement with semiconductor manufacturer Microsemi to resolve the agency's transfer pricing adjustment regarding an intercompany purchase of semiconductor products, according to U.S. Tax Court filings.
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September 26, 2025
Taxation With Representation: De Brauw, Hengeler Mueller
In this week's Taxation With Representation, power grid operator TenneT Holding sells a stake in its German transmission business to institutional investors, Pfizer Inc. acquires biotechnology company Metsera Inc., and Dutch brewer Heineken NV buys most of Costa Rica's FIFCO beverage and retail operations.
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September 25, 2025
Perrigo Mostly Beats US In $163M Tax Refund Dispute
A Michigan federal court largely sided Thursday with pharmaceutical company Perrigo in a $163 million tax refund case, rejecting the government's claim that the company's transactions with a foreign entity lacked economic substance and were meant only to avoid taxes.
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September 25, 2025
Finland Plans To Raise Taxes On Soft Drinks, Mined Minerals
The Finnish government will increase its soft drink tax based on different levels of sugar content, while also nearly quadrupling its mining mineral tax, the Ministry of Finance announced Thursday.
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September 25, 2025
EU, US Trade Officials Meeting On Tariff Deal
In advance of a meeting Thursday between European and U.S. trade officials, European Commission trade spokesman said discussion topics could include possible rate reductions and tariff exemptions for additional goods under an evolving bilateral framework trade agreement.
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September 25, 2025
Philippine Airlines Challenges $7.1M IRS Bill In Tax Court
Philippine Airlines is disputing $7.1 million in income taxes assessed by the IRS, claiming the agency erred by determining that the airline's gross transportation income was not exempt under the U.S.-Philippines tax treaty, according to a petition filed in the U.S. Tax Court.
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September 25, 2025
Fed. Circ. Upholds China Tariffs From Trump's 1st Term
The Federal Circuit on Thursday blessed a large batch of tariffs on Chinese goods installed by President Donald Trump during his first White House term, turning away a host of importers' claims that the levies had been imposed illegally.
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September 25, 2025
Gov't Warns Of Tax Hit From Pre-Budget Pension Withdrawals
British pension savers that pull cash out of their retirement pots due to pre-Budget jitters will eat into a portion of their tax-free allowance, even if they later change their mind and cancel the withdrawal, the government confirmed Thursday.
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September 25, 2025
Fladgate Says Founders Of Claims Biz Pocketed Tax Refunds
Fladgate LLP has told a London court that the founders of a claims management company swindled tax credits linked to the firm's work on group litigation involving property search companies.
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September 24, 2025
Execs Breached Danish Deal In $2B Tax Case, Court Says
Three men claiming to be pension plan executives who struck a civil settlement with the Danish taxing authority over their role in a $2 billion tax fraud scheme breached their settlement agreement, a New York federal court found, saying the men had not paid back the amount they promised.
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September 24, 2025
Ill. Justices Won't Hear Pepsi's $2.1M Tax Penalty Case
An Illinois appeals court decision allowing $2.1 million in penalties against PepsiCo for categorizing Frito-Lay expatriates' compensation as foreign payroll will stand, as the state's highest court declined to review the dispute Wednesday.
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September 24, 2025
EU Committee Adopts Economic Presence Rules For Biz Tax
Multinational companies with revenues above €1 million ($1.17 million) from a European Union country would be deemed to have a permanent establishment subject to taxation there under amendments that a European Parliament committee incorporated into a proposed corporate tax base directive Wednesday.
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September 24, 2025
Senate Finance Panel To Hold Digital Assets Taxation Hearing
The Senate Finance Committee will hold a hearing with digital asset experts on Oct. 1 to examine the tax treatment of income derived from such assets, Committee Chairman Mike Crapo, R-Idaho, announced Wednesday.
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September 24, 2025
EU Commission Provides Guidance For Blocwide VAT Rules
The European Commission issued guidance Wednesday to help European Union member states enact blocwide value-added tax rules for the digital economy, including real-time e-invoicing on cross-border transactions.
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September 24, 2025
Hotel Boss Banned From Directorship Over £1.6M Tax Debt
The former boss of a hotel on the Isle of Skye has been banned as a company director over tax debts totaling around £1.6 million ($2.2 million) to Britain's revenue authority, the U.K.'s insolvency agency said Wednesday.
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September 23, 2025
Trump Tariffs Are Constitutional, President's Allies Tell Justices
Two Republican lawmakers and two allied nonprofit groups told the U.S. Supreme Court on Tuesday that it should allow President Donald Trump's emergency tariffs authorized under the International Emergency Economic Powers Act.
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September 23, 2025
EU Eyeing Country-Level Min. Tax Exemption For US Cos.
The European Union's preferred method for accommodating the U.S. proposal to exempt American companies from the 15% global minimum tax's international provisions would be to allow a conditional safe harbor that member countries would need to enact individually, a top EU tax official told lawmakers Tuesday.
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September 23, 2025
Albania Becomes 10th To Sign Min. Tax Payments Treaty
Albania became the 10th country to sign a multilateral treaty aimed at carrying out a 9% minimum tax on income sent from signatory jurisdictions to low-taxed entities within a corporate group, the Organization for Economic Cooperation and Development said Tuesday.
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September 23, 2025
Full Effects Of US Tariffs 'Yet To Be Felt,' OECD Report Says
Economic growth in the U.S. is expected to dip in 2026 partly because of global trade tensions, the full effects of which "have yet to be felt," the Organization for Economic Cooperation and Development reported Tuesday.
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September 23, 2025
UBS Settles Long Tax Dispute With France For An €835M Fine
UBS has resolved its long-running tax dispute with France over cross-border transactions, agreeing to pay a fine of €835 million ($985 million), the company said Tuesday.
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September 22, 2025
The Tax Angle: Green Energy Permits, Enhanced ACA Credits
From a look at permitting delays holding up solar and wind tax credit projects to uncertainty surrounding the renewal of Affordable Care Act enhanced premium tax credits, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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September 22, 2025
VC Partner Fights IRS Summonses Tied To Korean Tax Probe
A partner at a U.S. venture capital firm urged a California federal court to quash IRS summonses seeking information on his bank accounts in connection with his tax liabilities in South Korea, saying the agency failed to meet requirements for enforcing the summonses.
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September 22, 2025
UAE Commits To OECD Crypto-Asset Reporting Rules
The United Arab Emirates has signed on to a multilateral automatic information exchange system under the Organization for Economic Cooperation and Development's global digital asset reporting framework, the country's Ministry of Finance announced.
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September 22, 2025
Perkins Coie Adds Former US Treasury Tax Policy Atty In DC
Perkins Coie LLP has brought on a tax attorney who worked in the U.S. Department of the Treasury's Office of Tax Policy, where he handled work related to laws such as the Inflation Reduction Act and the One Big Beautiful Bill Act, the firm announced Monday.
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September 22, 2025
Australia Focusing On Privately Owned, Wealthy Tax Groups
The Australian Taxation Office on Monday outlined key areas the agency is focusing on regarding privately owned and wealthy groups, including ensuring transparency through the comprehensive reporting of tax and shareholder information.
Expert Analysis
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5 Litigation Funding Trends To Note In 2025
Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.
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Rethinking Litigation Risk And What It Really Means To Win
Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.
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Small Biz Caught In Corporate Transparency Act Crossfire
Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.
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No, Litigation Funders Are Not 'Fleeing' The District Of Del.
A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.
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5 E-Discovery Predictions For 2025 And Beyond
In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.
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What's Ahead As Transparency Act Comes To A Crossroads
Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.
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7 Ways 2nd Trump Administration May Affect Partner Hiring
President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.
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E-Discovery Quarterly: Rulings On Custodian Selection
Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.
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Exploring Venue Strategy For Trump-Era Regulatory Litigation
Litigation will likely play a prominent role in shaping policy outcomes during the second Trump administration, and stakeholders have several tools at their disposal to steer regulatory litigation toward more favorable venues, say attorneys at Covington.
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An Associate's Guide To Career Development In 2025
As the new year begins, associates at all levels should consider establishing career metrics, fostering key relationships and employing other specific strategies to help move through the complexities of the legal profession with confidence and emerge as trailblazers, say EJ Stern and Amanda George at Fractional Law Firm.
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Making The Pitch To Grow Your Company's Legal Team
In a compressed economy, convincing the C-suite to invest in additional legal talent can be a herculean task, but a convincing pitch — supported by metrics and cost analyses — may help in-house counsel justify the growth of their team, say Elizabeth Smith and Roger Garceau at Major Lindsey.
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Tax Court Should Update Framework For Defining Insurance
The U.S. Tax Court's unnecessary determination in Royalty Management Insurance v. Commissioner that a fraudulent transaction did not contain the hallmarks of a legitimate insurance transaction applies an outdated analysis that threatens the captive insurance sector and illustrates the need for a more modern framework to define true insurance, says Matthew Queen at the Queen Firm.
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When US Privilege Law Applies To Docs Made Outside The US
As globalization manifests itself in disputes over foreign-created documents, a California federal court’s recent trademark decision illustrates nuances of both U.S. privilege frameworks and foreign evidentiary protections that attorneys must increasingly bear in mind, say attorneys at Hunton.