International
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July 21, 2025
Family Claims Bad Tax Advice Led To Costly HMRC Bills
The trustees of family trusts accused a U.K. accounting firm of giving them negligent advice that led to unexpected inheritance taxes and penalties owed to HM Revenue & Customs, according to a claim filed in a London court.
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July 21, 2025
UK Launches Online Service Available For 35M Taxpayers
HM Revenue & Customs launched an online Pay As You Earn portal Monday, available to 35 million U.K. taxpayers, that the British revenue agency said is intended to make it easier to check on tax information as part of HMRC's overall digital transformation.
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July 21, 2025
Paul Hastings Boosts Tax Team In NY With Ex-Kirkland Atty
Paul Hastings LLP announced Monday that a former Kirkland & Ellis LLP attorney is bringing her tax practice to its New York office in a move the firm says will bolster its ability to guide clients through complex deals like mergers, acquisitions and private equity transactions.
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July 18, 2025
Law360 Names 2025's Top Attorneys Under 40
Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age.
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July 18, 2025
Trade Legal Matters To Watch: Midyear Report
Aggressive, sweeping tariff actions have defined the first six months of President Donald Trump's second term, altering the global trade environment in attempts to return manufacturing to the U.S. and reset trading deficits, but legal challenges to certain duties may obstruct Trump's long-term trade strategy in ongoing negotiations later this year.
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July 18, 2025
HMRC Urged To Broaden Reporting Of Uncertain Tax Positions
HM Revenue & Customs may need to change its rules for when taxpayers must disclose uncertain tax positions they've taken to the tax authority, according to a report by a nonprofit research organization.
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July 18, 2025
IRS Offers Guidance On Use Of Transfer Pricing Exception
Taxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday.
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July 18, 2025
Trump Asks Supreme Court To Decline Early Tariff Challenge
President Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts.
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July 18, 2025
Western Union Says IRS Used Flawed Rule To Hike Income
The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.
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July 18, 2025
Taxation With Representation: Wachtell, Slaughter And May
In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.
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July 18, 2025
European Tax Policy To Watch In 2nd Half Of 2025
The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months.
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July 18, 2025
EU To Make Foreign Traders Liable For VAT On Imports
Foreign companies, rather than consumers, will become liable for value-added tax on imports to the European Union beginning July 2028 under a directive adopted Friday by the bloc's council of member states, according to a news release.
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July 18, 2025
Oman, Trinidad And Tobago 'Largely Compliant,' OECD Says
Reviews of the implementation of tax transparency measures in Oman and in Trinidad and Tobago found both nations "largely compliant" with Organization for Economic Cooperation and Development standards, the OECD said Friday.
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July 17, 2025
Canada Mulling Changes To Ability To Rewrite Transactions
Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.
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July 17, 2025
US Negotiating Global Min. Tax Carveout Accord, Official Says
The U.S. hasn't yet secured an agreement with other countries to exempt its companies from the international parts of the 15% global minimum tax despite reaching an "understanding" with the Group of 7 nations, but wider negotiations have begun, a U.S. Treasury Department official said Thursday.
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July 17, 2025
EU Warns Dutch Over Tax Breaks Favoring Foreign Investment
The Netherlands may have to face the Court of Justice of the European Union if it does not amend a tax measure that provides incentives for investment in foreign companies over domestic businesses, the European Commission announced Thursday.
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July 17, 2025
EU Lawmakers Push For Tax Data Hub To Combat Evasion
Members of the European Parliament approved proposals for tax changes across the European Union, including a tax data hub to streamline compliance across the bloc and help combat tax avoidance and evasion.
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July 17, 2025
US Challenge To Belgian Minimum Tax Rules Heads To ECJ
A Belgian court said Thursday it has asked the European Union's highest court to weigh in on a U.S. industry group's challenge to the country's global minimum tax rules.
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July 17, 2025
Tax Info Swaps Have Generated €135B Since 2009, OECD Says
The international push for widespread adoption of tax transparency measures such as exchanges of information has led to €135 billion ($156 billion) in added revenue — including taxes, penalties and interest — since 2009, the Organization for Economic Cooperation and Development said Thursday.
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July 17, 2025
Australia Seeks Comments On Pillar 2 Guidance
The Australian Taxation Office is looking for public comments on a pair of draft guidelines related to the country's adoption of the Organization for Economic Cooperation and Development's Pillar Two global corporate minimum tax on large multinational entities.
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July 16, 2025
OECD Mulling Tweaks To Arm's-Length Range Guidance
The Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday.
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July 16, 2025
Tax Losses Back Retired Prof's FBAR Penalties, US Says
A retired professor's admission in U.S. Tax Court that his failure to report his foreign bank accounts caused tax losses shows that a California federal court should affirm tax penalties against him of more than $400,000, the U.S. government said.
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July 16, 2025
EU Proposes New Tax On Large Cos. In Budget For 2028-2034
The European Commission raised the idea Wednesday of a new tax on all companies that operate in the European Union with more than €100 million ($116 million) in annual revenue to augment its €2 trillion budget proposal for 2028 through 2034.
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July 16, 2025
German Chancellor Calls For EU Halt To Global Minimum Tax
German Chancellor Friedrich Merz has called for the suspension of the European Union's rollout of the global corporate minimum tax, a German newspaper reported Wednesday.
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July 16, 2025
USTR To Probe Brazil's Trade Practices For Possible Tariffs
The Office of the U.S. Trade Representative announced Tuesday evening it will launch an investigation into Brazil's trade practices to determine whether tariff actions could be necessary after a request by President Donald Trump and prior tariff threats.
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.