International
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June 18, 2025
Seychelles Co. Brings $22M Guinea Award To DC Circ.
A consulting company is asking the D.C. Circuit to revive its bid to enforce a $22 million arbitration award against the Republic of Guinea, contending that the lower court was wrong to toss the case on jurisdictional grounds.
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June 18, 2025
Fed. Circ. OKs How Commerce Filled Blank In Steel Duty Case
The U.S. Department of Commerce may apply adverse facts to a company that fails to propose reasonable alternatives for collecting information that would be unreasonably hard to obtain in an antidumping investigation, the Federal Circuit said in a precedential opinion upholding steel duties on German companies.
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June 18, 2025
£20M Buybacks Weren't Mainly For Tax Benefit, UK Court Says
Obtaining a tax advantage wasn't the main purpose of two businessmen arranging £20 million ($26.8 million) in share buybacks, despite that being the effect, so they aren't liable for an anti-avoidance action by HM Revenue & Customs, the U.K. Upper Tribunal said in overturning a lower court's ruling.
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June 18, 2025
Billabong Founder Must Split Costs In AU$50M Tax Bill Loss
The founder of surf brand Billabong and the Australian tax authority must split the costs of litigation that ultimately put the founder on the hook for AU$50 million ($33 million) in taxes, the Federal Court of Australia held Wednesday.
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June 18, 2025
Mich. Housing Co-Op Suit On Hold After Disclosure Exemption
A Michigan federal judge hit pause on a lawsuit from a group of housing cooperatives to escape requirements of the Corporate Transparency Act after the Financial Crimes Enforcement Network said it would give U.S.-based entities a break from the rules.
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June 18, 2025
EU Refers Portugal To Court Over Excise Duty Harmonization
Portugal is three-and-a-half years late in transposing a pair of European Union directives related to excise duties into domestic law, the European Commission said Wednesday, referring the country to the European Court of Justice to face a potential fine, among other announced infringement decisions.
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June 17, 2025
Wyden Vows To Fight For Energy Credits Facing GOP Repeal
The top Senate Democratic tax writer vowed Tuesday to try to protect clean energy tax provisions of the 2022 Inflation Reduction Act that would face an early repeal under the sweeping tax and budget legislation released by Republicans in the Senate Finance Committee.
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June 17, 2025
AbbVie Can Get Deduction For $1.6B Payment, Tax Court Says
AbbVie can claim a deduction for the $1.6 billion it paid under a merger agreement, the U.S. Tax Court held Tuesday, rejecting the IRS' contention that the payment was a capital loss that raised the pharmaceutical giant's tax bill by $572 million.
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June 17, 2025
Ill. Toy Makers Seek Justices' Early Review Of Trump Tariff Suit
Illinois-based toy makers challenging President Donald Trump's emergency tariffs on Tuesday requested the U.S. Supreme Court consider their case before it is reviewed by the D.C. Circuit, arguing a stay to an injunction is allowing duty collections to continue and is damaging the companies.
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June 17, 2025
DOJ Seeks 5 Years, $10M For Fla. Man Hiding Swiss Accounts
A Miami man who lied to authorities and others for decades about his Swiss bank accounts should pay $10.3 million in unpaid taxes and face a maximum five-year prison sentence based on his plea agreement, the U.S. Department of Justice told a Florida federal court.
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June 17, 2025
Poland Calls For EU Digital Services Tax In Revenue Package
The European Commission should consider previous proposals for a digital services tax regime across the European Union as part of its revenue package, the Polish presidency of the Council of the EU said in a report.
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June 17, 2025
Tax Admins In OECD Group Largely Using AI, Report Says
Of the 54 members of the OECD's Forum on Tax Administration, over 70% are using artifical intelligence in some way to improve services, most often to detect tax evasion and fraud, the OECD said in a report Tuesday.
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June 17, 2025
IRS Updates Prefiling Program For Large Biz, Int'l Taxpayers
The Internal Revenue Service has made several changes to its prefiling agreement program, including updating the guidelines to help large corporate and international taxpayers flag potential issues before submitting returns, the agency said Tuesday.
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June 17, 2025
Swedish Tax Agency Asks For Greater Enforcement Powers
The Swedish Tax Agency is looking to enhance its ability to address tax crimes, it told the country's Ministry of Finance on Tuesday, sharing proposals that would strengthen its law enforcement powers and grant it the power to store biometric data.
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June 17, 2025
Norway Looks To Adopt Updated Pillar 2 Guidance
The Norwegian Ministry of Finance proposed updating its adoption of the Organization for Economic Cooperation and Development's global minimum tax to integrate administrative guidance issued over the past year.
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June 17, 2025
HMRC Challenges Tax Treatment Of Partnership Awards
HM Revenue & Customs told the U.K. Supreme Court on Tuesday that partnership awards allocated to a corporate entity and then distributed to partners should be taxed as if they were allocated to individual members.
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June 16, 2025
US, UK Reach Trade Deal On Cars; Steel Tariffs Still Unresolved
President Donald Trump signed an order Monday enshrining the nation's new trade deal with U.K. governments under which the U.S. agreed to slash tariffs on 100,000 imported U.K. automobiles and auto parts, while eliminating tariffs on certain aerospace products but leaving steel and pharmaceuticals tariffs for future negotiations.
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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.
Expert Analysis
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Atty Well-Being Efforts Ignore Root Causes Of The Problem
The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.
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Unpacking The Circuit Split Over A Federal Atty Fee Rule
Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.
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After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1
The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.
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Recruitment Trends In Emerging Law Firm Frontiers
BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.
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How Associates Can Build A Professional Image
As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.
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Firms Must Rethink How They Train New Lawyers In AI Age
As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.
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Think Like A Lawyer: Always Be Closing
When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.
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Lean Into The 'Great Restoration' To Retain Legal Talent
As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.
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Fishing Makes Me A Better Lawyer
Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge at Robinson Bradshaw.
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A Healthier Legal Industry Starts With Emotional Intelligence
The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.
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To Make Your Legal Writing Clear, Emulate A Master Chef
To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.