International
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June 16, 2025
Senate Bill Sticks With TCJA's $10,000 SALT Cap
The Senate Finance Committee's tax portion of the chamber's budget reconciliation bill released Monday follows the House's lead on some provisions while breaking with the lower chamber's hard-won compromises on an increased state and local tax deduction and the phaseout of green energy credits.
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June 16, 2025
The Tax Angle: EITC Audits, UTPR, Energy Credits
From a look at Republicans' efforts to audit the earned income tax credit, complaints about unfair foreign taxation under the OECD's Pillar Two framework and Democrats' push against Republican plans to strip the Inflation Reduction Act's energy credits from the code, here's a peek into a reporter's notebook on a few developing tax stories.
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June 16, 2025
Book Profits Much Higher Than Taxable Income, Paper Says
Companies report about three to four times higher profits on financial statements for investors compared with the taxable income they report to authorities, a phenomenon most prevalent among multinational corporations, which suggests book profits underestimate profit shifting, the EU Tax Observatory said Monday.
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June 16, 2025
G7 Could Raise $214B Yearly From 2% Wealth Tax, Group Says
The Group of Seven countries could raise $214 billion a year if each government imposed a 2% wealth tax on fortunes above $100 million, with the U.S. potentially raising $161 billion by itself, a group of wealthy Canadians said Monday in support of such measures.
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June 16, 2025
Trump Eyes Trade Deal With Canada During G7 Summit Talks
President Donald Trump said at the G7 summit Monday that he would work with Canadian Prime Minister Mark Carney to reach a trade deal, raising the possibility that an agreement could be struck before the multilateral meeting concludes.
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June 16, 2025
Wealth Taxes, End Of Profit Shifting Worth $2.6T, Group Says
World governments could raise about $2.6 trillion annually, more than enough revenue to finance most climate-related needs, if they collectively adopted low-rate wealth taxes beginning with the richest 0.5% and stopped multinational corporations from shifting profits, the Tax Justice Network said Monday.
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June 16, 2025
HMRC Warns Umbrella Co. Employees Of Tax Risks
Employees and contractors of temporary worker agencies known as umbrella companies need to be vigilant to make sure they aren't unwittingly involving themselves in tax avoidance schemes, HM Revenue & Customs said, laying out ways to spot such avoidance issues.
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June 16, 2025
OECD Offers Template For Tax Crime Investigation Guidance
The Organization for Economic Cooperation and Development released standards Monday for jurisdictions to use when creating manuals to guide government agencies through tax crime investigations, with the aim of creating more efficient and effective processes, it said.
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June 16, 2025
Colombian Taxpayers Owe $34M In Foreign Exchange Debts
Nearly 290 Colombian taxpayers have accumulated roughly 142.2 billion Colombian pesos ($34.6 million) in unpaid tax debts related to their foreign exchange transactions, the country's tax authority said, offering possible reductions for their associated penalties.
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June 13, 2025
US-China Trade Talks Resume, Draw Mixed Reviews
Despite the promise of new trade talks held this week by the U.S. and China, the long-term strategic view of many companies remains concern over the obstacles they continue to face, especially if they must diversify supply chains that heavily rely on China.
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June 13, 2025
211K Suspicious Transaction Reports Filed In France In 2024
France's anti-money laundering unit received over 211,000 reports of suspicious financial transactions in 2024, making up the vast majority of the more than 215,000 reports received by the unit, an over 13% increase from the year prior, the country's finance ministry said Friday.
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June 13, 2025
Israeli Businessman Found Liable For $3.2M Over FBARs
An Israeli businessman who was held in contempt of court for dodging discovery requests is liable for $3.24 million in penalties and interest for willfully failing to report his foreign bank accounts, according to a Washington federal court.
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June 13, 2025
UK Businessman Defends Asset Transfer As Tax Strategy
A British businessman denied that he transferred a company to his son to defraud a creditor, arguing it was part of a long-term tax strategy rather than a tactic to avoid repaying £4.7 million ($6.4 million) in debt.
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June 13, 2025
Tax Credit Sales Would Be Difficult To Insure Under House Bill
House Republicans' sweeping budget bill proposes to promptly scale back the clean energy tax incentives established by the 2022 climate law, a move that would make it difficult for tax insurers to back project development deals that want to sell their tax credits for cash.
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June 13, 2025
Taxation With Representation: Debevoise, Latham, Paul Weiss
In this week's Taxation With Representation, Brown & Brown Inc. buys Accession Risk Management Group Inc., Allison Transmission Holdings Inc. acquires Dana Inc.'s off-highway unit, Qualcomm Inc. buys Alphawave IP, and Warner Bros. Discovery announced it will split into two publicly traded companies.
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June 13, 2025
Private Schools Lose Bid To Overturn VAT On Fees
The U.K. government has not breached human rights law by extending value-added tax to private school fees, the High Court ruled Friday, rejecting claims brought by a group of schools and families.
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June 12, 2025
Broader German Tax Base Key To Fiscal Growth, OECD Says
Germany should consider multiple avenues to broaden its tax base in the name of ensuring medium-term fiscal stability, the Organization for Economic Cooperation and Development recommended Thursday, saying such changes could also lead to lower labor taxation.
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June 12, 2025
China Agrees To Loosen Rare Earth Restrictions, US Says
Chinese trade negotiators have agreed to lift export controls on rare-earth elements in exchange for the U.S. walking back a campaign to revoke visas for Chinese students, according to statements by U.S. officials, which experts said leave key issues unresolved.
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June 12, 2025
UK Investors Sue Cricket Team Owner Over Claimed Tax Fraud
Three U.K.-based investors in an Indian Premier League cricket team are seeking £10 million ($13.6 million) in damages from the club's owner, claiming in a London court that he duped them over the tax implications of selling their shares in his business.
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June 12, 2025
Customs Missteps Don't Void VAT Exemption, ECJ Says
A horse owner can still claim a value-added tax exemption if she was merely negligent, rather than deceitful, in failing to declare her horses with Swedish customs officials, the European Court of Justice held Thursday.
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June 12, 2025
France Increased Tax Fraud Penalties By €1B In 2024
France's tax authority meted out €16.7 billion ($19.3 billion) in tax fraud duties and penalties in 2024, a €1 billion increase over the year prior, the head of the agency said Thursday.
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June 11, 2025
Russia Must Face $5B Yukos Award Suit, DC Judge Rules
At D.C. federal judge on Wednesday denied Russia's bid to nix litigation filed by the financing arm of Yukos Oil Co. to enforce a nearly $5 billion arbitral award, saying the Kremlin's jurisdictional objections fell short.
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June 11, 2025
US Consultant In France Must Pay $2M In FBAR Penalties
An American energy consultant residing in France must pay more than $2 million in penalties for purposely not disclosing foreign bank accounts that held more than $3 million, as opposed to the under $30,000 initially reported, a D.C. federal court ruled.
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June 11, 2025
House Budget Would Strong-Arm Foreign Gov'ts, Experts Say
The U.S. House-passed budget would discard the tax-exempt status of foreign governments and entities connected to them, such as sovereign wealth funds, and impose escalating tax rates if those countries employ fiscal policies that lawmakers consider unfair, according to several experts.
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June 11, 2025
Senate Dems' Bill Would Bar GILTI For 'Round-Tripped' Income
Income that is "round-tripped" to obtain tax advantages would become ineligible for the half-off corporate tax rate under the global intangible low-taxed income regime, based on a bill introduced Wednesday by Sen. Ron Wyden, D-Ore., and three other Senate Democrats.
Expert Analysis
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.
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What's Next For Russia Sanctions After Task Force Disbanded
Attorney General Pam Bondi’s recent disbanding of Task Force KleptoCapture, which was initially aimed at seizing Russian oligarchs’ funds and assets, is unlikely to mean the end of Russia sanctions enforcement and other economic countermeasures, as the architecture for criminal enforcement remains in place, say attorneys at BakerHostetler.
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How Law Firms Can Counteract The Loneliness Epidemic
The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.
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5 Keys To Building Stronger Attorney-Client Relationships
Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.
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Attorneys Must Act Now To Protect Judicial Independence
Given the Trump administration's recent moves threatening the independence of the judiciary, including efforts to impeach judges who ruled against executive actions, lawyers must protect the rule of law and resist attempts to dilute the judicial branch’s authority, says attorney Bhavleen Sabharwal.
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Rethinking 'No Comment' For Clients Facing Public Crises
“No comment” is no longer a cost-free or even a viable public communications strategy for companies in crisis, and counsel must tailor their guidance based on a variety of competing factors to help clients emerge successfully, says Robert Bowers at Moore & Van Allen.
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Reading The Tea Leaves On Mexico, Canada And China Tariffs
It's still unclear whether the delay in the imposition of U.S. tariffs on Canadian and Mexican imports will result in negotiated resolutions or a full-on trade war, but the outcome may hinge on continuing negotiations and the Trump administration's possible plans for tariff revenues, say attorneys at Eversheds Sutherland.
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How Design Thinking Can Help Lawyers Find Purpose In Work
Lawyers everywhere are feeling overwhelmed amid mass government layoffs, increasing political instability and a justice system stretched to its limits — but a design-thinking framework can help attorneys navigate this uncertainty and find meaning in their work, say law professors at the University of Michigan.
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The Pros And Cons Of A 2nd Trump Term For UK Tech Sector
While U.S. President Donald Trump’s protectionist stance on trade could disrupt global supply chains on which many U.K. tech firms are reliant, anticipated deregulation could provide fertile ground for investment and growth, and the U.K. tech sector is bracing for a mix of opportunities, say lawyers at Shoosmiths.
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Corp. Transparency Act's Future Under Treasury's Bessent
The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.
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A Look At A Possible Corporate Transparency Act Exemption
Attorneys at Kirkland offer a deep dive into the application of the Corporate Transparency Act's reporting requirements specifically to U.S.-domiciled co-issuers in typical collateralized loan obligation transactions, and consider whether such issuers may be able to assert an exemption from the CTA's reporting requirements.