International
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November 05, 2025
Justices Skeptical About Trump's Emergency Tariff Authority
Several U.S. Supreme Court justices asked the government to defend why well-established judicial doctrines shouldn't limit President Donald Trump's tariffs imposed under the International Emergency Economic Powers Act during oral arguments Wednesday, casting doubt on whether they believe the law provides that kind of authority.
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November 05, 2025
Poland Publishes Draft Of Global Pillar 2 Information Return
Poland's Ministry of Finance on Wednesday published a draft of legislation to implement a first-of-its-kind global information return that countries will use to carry out an international 15% minimum corporate tax agreement known as Pillar Two.
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November 05, 2025
Switzerland Adopts Tax Treaty With Zimbabwe
Switzerland has adopted the dispatch on the double taxation agreement with Zimbabwe as part of expanding its tax treaty network in the region, the Swiss government announced Wednesday.
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November 04, 2025
Malawi Asks Judge To Undo Halt Of Gem Export Tax Probe
Malawi asked a Washington federal judge to reconsider his recent decision to bar the country from pursuing discovery against a gemstone company that it alleges partnered with a mining outfit to dodge billions of dollars in taxes and export royalties.
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November 04, 2025
Former Eaton CFO Says Bond Investors Needed Reassurance
Eaton Corp.'s former chief financial officer chronicled on Tuesday the company's efforts to finance its 2012 acquisition of Ireland-based Cooper Industries, describing an atmosphere of leery bond investors after the Great Recession of 2008, on the second day of the company's U.S. Tax Court trial.
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November 04, 2025
Canadian Budget Proposes Slew Of Corporate Tax Breaks
Canada's government aims to introduce immediate expensing for manufacturing, energy, data network infrastructure and scientific research while reinstating first-year write-offs for most capital assets, which would lower its marginal effective corporate tax rate to 13.2%, according to a budget presented late Tuesday.
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November 04, 2025
3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs
A U.S. Supreme Court ruling that gutted deference to agencies took center stage in the Eighth Circuit's recent decision that backed 3M's challenge to transfer pricing rules, signaling the strict statutory analysis that courts may now apply to tax regulations.
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November 04, 2025
Higher Min. Tax Could Help Stem Inequality, G20 Report Says
A higher minimum corporate tax rate with fewer carveouts, tougher inheritance taxes and a global asset registry would help stem economic inequality seen in the vast majority of countries, according to the Group of 20 nations' first report on inequality, published Tuesday.
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November 04, 2025
Insolvent UK Co.'s Ex-Director Fights £2M VAT Fraud Case
The former director of a company in liquidation denied an insolvency specialist's claims that he took part in a value-added tax fraud at the business and is liable for paying about £2 million ($2.6 million), saying the U.K. tax authority has withdrawn its liability notices against him.
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November 03, 2025
Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told
An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determining a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."
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November 03, 2025
4 Ways Justices' Jarkesy Ruling Could Affect Tax Controversy
As lower courts have begun to weigh the U.S. Supreme Court’s 2024 ruling that the SEC’s imposition of civil penalties without a jury trial was unconstitutional, attorneys say the decision could reshape tax disputes and potentially force the IRS to reconsider its approach to enforcement. Here, Law360 examines potential ways the Jarkesy precedent could influence tax controversy.
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November 03, 2025
2 Doctrines Likely To Direct Justices' Review Of Trump Tariffs
When the U.S. Supreme Court hears oral arguments Wednesday over whether President Donald Trump can impose tariffs under the International Emergency Economic Powers Act, it will likely test two doctrines the justices have recently considered: the major questions and nondelegation doctrines.
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November 03, 2025
Kenya Seeks Input On Regs For Min. Tax, Advance Pricing
Kenya's tax authority invited feedback Monday for draft regulations covering its domestic minimum top-up tax and a separate set of draft regulations for its program to offer advance pricing agreements.
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November 03, 2025
US, China Agree To Cut Tariffs, Restrictions In Trade Truce
The United States and China have agreed to a one-year suspension of certain tariffs, export controls and retaliatory trade restrictions, according to statements by the White House and China's Ministry of Commerce.
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November 03, 2025
Veteran Tax Controversy Atty Moves Team To Kostelanetz
A longtime New Jersey tax attorney and three of his associates have joined Kostelanetz LLP, the boutique tax firm announced Monday, saying it expected them to bolster its tax controversy practice and add to its commitment to volunteer work and legal education.
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November 03, 2025
ECJ Asked To Clarify State Aid Tax Rules For Nonprofits
A German court has asked the European Union's top court to rule on whether a tax relief scheme for nonprofit service corporations amounts to state aid under EU law, according to a notice published Monday.
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November 03, 2025
€1.2B Of Campari Owner's Shares Seized In Italian Tax Probe
Italian authorities have seized about €1.2 billion ($1.4 billion) worth of shares in Campari Group as part of a tax investigation into the drink maker's Luxembourg-based majority stakeholder, which announced the asset seizure.
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October 31, 2025
Int'l Tax In October: Deal With China, Halt To Canada Talks
A tentative deal to reduce American tariffs on Chinese goods, ruptured trade talks between the U.S. and Canada, court defeats for the Danish and U.S. tax administrations and an end to the European Union's plan for a financial transaction tax topped the list of international tax news in October. Here, Law360 looks at the biggest developments from the past month.
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October 31, 2025
Up Next At High Court: Tariffs, Fugitives & Contractor Liability
The U.S. Supreme Court will begin its November oral argument session Monday, during which the justices will consider President Donald Trump's authority to impose tariffs on foreign countries under an emergency statute, whether military contractors can be held liable for alleged breaches of contracts in war zones, and if there are time limits for litigants who want to vacate a void judgment. Here, Law360 breaks down the week's oral arguments.
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October 31, 2025
OECD Reports Rise In Failed Advance Pricing Agreements
The number of advance pricing agreements that were rejected or closed without an accord rose 19% last year compared with the previous year, and slightly fewer agreements were granted overall, the Organization for Economic Cooperation and Developmen said Friday.
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October 31, 2025
UK Co. Can't Shake £8.4M Tax On Goods Imported For Repair
A U.K. subsidiary of a U.S. industrial equipment company isn't entitled to recover roughly £8.4 million ($11 million) in value-added tax on goods it brought into the U.K. for repair and servicing, a London tribunal ruled.
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October 31, 2025
OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases
Tax authorities began more than 2,500 mutual agreement procedure cases last year involving transfer pricing, a record number representing a 29% increase from the previous year, the Organization for Economic Cooperation and Development said Friday.
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October 31, 2025
Taxation With Representation: Skadden, Davis Polk
In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.
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October 31, 2025
Australia Issues Guidance On Public Country-By-Country Law
Australia issued guidance Friday on how to comply with its public country-by-country reporting law, including filing instructions, formatting and the information required to be disclosed.
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October 31, 2025
5 Indicted In Germany In €188M VAT Fraud Scheme
Five German residents have been indicted on charges related to their participation in a €188 million ($217 million) value-added tax fraud scheme, European Union authorities said Friday.
Expert Analysis
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Accountant-Owned Law Firms Could Blur Ethical Lines
KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.
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AI Will Soon Transform The E-Discovery Industrial Complex
Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.
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Unpacking The Legal Foundation Of Trump's New Trade War
President Donald Trump's recent executive orders and proclamations regarding emergencies at the U.S. border are based on statutory powers enabling a president to address extraordinary external threats — and could be used to fend off legal challenges to the tariffs levied on Mexican and Canadian goods, says Chris Zona at Mandelbaum Barrett.
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When Innovation Overwhelms The Rule Of Law
In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.
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Imagine The Possibilities Of Openly Autistic Lawyering
Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.
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Litigation Funding Disclosure Debate: Strategy Considerations
In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.
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5 Ways To Create Effective Mock Assignments For Associates
In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.
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Mentorship Resolutions For The New Year
Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.
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Tax Directive Marks Milestone In Harmonizing EU System
The Council of the European Union’s recently adopted tax directive is a significant step toward streamlining and modernizing procedures for member states, and will greatly reduce administrative burden and compliance costs for cross-border investors, says Martin Phelan at Simmons & Simmons.
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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.