International
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June 02, 2025
CJEU Set To Hear SocGen's Case In Swedish Tax Dispute
The Court of Justice of the European Union said Monday that it will hear the case of French banking giant Société Générale SA against the Swedish tax authority over the taxation of nonresident companies under the European treaty.
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June 02, 2025
OECD Releases Consolidated Text Of Data-Swap Guidance
The Organization for Economic Cooperation and Development published consolidated text of a global reporting standard Monday to help tax administrations exchange financial information about individuals who may be trying to hide money from their tax authorities at home.
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June 02, 2025
IRS To Hold Hearing On Sourcing Cloud Transaction Income
The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.
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May 30, 2025
US-China Trade Talks Could Resume After Stall Over Minerals
Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.
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May 30, 2025
Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight
An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.
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May 30, 2025
HMRC Correctly Handled Land Tax Dodge, UK Court Says
HM Revenue & Customs followed the correct procedures to collect taxes on six individuals who attempted to dodge the U.K.'s land tax by transacting with a special purpose vehicle in Guernsey, the Upper Tribunal ruled.
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May 30, 2025
Isle Of Man Agrees To Work With UK Against Tax Avoidance
Isle of Man authorities reached an agreement with the U.K. government to work together in a crackdown on promoters of tax avoidance schemes, according to a joint statement.
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May 30, 2025
UK Midsize Biz Owners Wary Of Risk Exposure, Report Says
Owners and operators of midsize U.K. businesses are just as wary of risk exposure in personal taxes as they are in business taxes except under certain circumstances, according to a report commissioned by HM Revenue & Customs.
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May 30, 2025
Taxation With Representation: Kirkland, Cravath, Latham
In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.
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May 29, 2025
DC Court Blocks Trump's Tariffs As Overreach Of Power
The International Emergency Economic Powers Act does not empower the president to impose tariffs, the D.C. federal district court said Thursday, ruling that President Donald Trump's global levies are unlawful and barring his administration from enforcing them on two toymakers who challenged the policies.
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May 29, 2025
Fed. Circ. Revives Trump Tariffs As It Weighs Appeal
The Federal Circuit temporarily reinstated President Donald Trump's global tariffs Thursday, a day after the U.S. Court of International Trade held that an emergency law did not give the president "unbounded authority" to impose the measures.
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May 29, 2025
Australia Outlines Compliance For Thin Capitalization Test
The Australian Taxation Office is looking for feedback on draft compliance guidance for corporations looking to use one of its new thin capitalization tests as they relate to cross-border financing arrangements, it said Thursday.
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May 29, 2025
£2.4B Employment Tax Credit Has Limited Value, Report Says
A U.K. employment tax credit worth around £2.4 billion ($3.2 billion) a year in payroll tax relief for businesses has limited value, according to a report commissioned by HM Revenue & Customs, with the smallest businesses reaping the most benefit.
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May 29, 2025
Biz Group Calls On EU To Resolve Pillar 2 Dispute With US
The European Union should work quickly to resolve problems with the Pillar Two global minimum corporate tax and its interaction with the U.S. tax system, the American Chamber of Commerce for the EU said.
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May 29, 2025
IRS Annual Gross Collections Top $5 Trillion For First Time
The Internal Revenue Service collected $5.1 trillion in gross revenue in fiscal year 2024, a 9% increase over last year's $4.7 trillion total, marking the first time the tax haul has been above $5 trillion, the agency said Thursday.
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May 29, 2025
US Tariffs Spark Profit Warnings For UK Pension Sponsors
British businesses might seek to tap into pension surpluses because of ongoing financial losses caused by U.S. tariffs, a professional services firm has warned.
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May 28, 2025
International Trade Court Strikes Down Trump's Tariffs
The International Emergency Economic Powers Act does not give the president the "unbounded authority" to impose tariffs on goods from nearly every country in the world, the U.S. Court of International Trade ruled Wednesday, handing a win to small businesses and states challenging some of President Donald Trump's steep tariffs.
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May 28, 2025
Fintech Group Warns Remittance Tax Will Hurt Consumers
The American Fintech Council sent a letter to members of Congress asking them to reconsider a proposed tax on remittances that is a part of the $3.8 trillion bill to extend and make permanent the Republican Party's 2017 tax overhaul law, also known as The One Big Beautiful Bill Act.
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May 28, 2025
4 Big Questions Raised By International Retaliatory Tax In GOP Bill
Republicans' evolving international retaliatory tax proposal has been viewed as an effort to influence foreign tax regimes and as a possible tool in global tax and trade talks, but it has sparked concerns that it could escalate a trade war or otherwise hurt the U.S. economy. Here, Law360 explores four questions raised by the proposal.
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May 28, 2025
$3.9 Trillion Price Tag On House Budget Bill's Tax Provisions
Tax provisions included in the House-passed budget reconciliation bill that would extend and make permanent many provisions in the 2017 tax overhaul would cost $3.9 trillion over the next decade, according to a report released Wednesday by the Joint Committee on Taxation.
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May 28, 2025
Mexico Collected $982M From Transfer Pricing Last Year
Mexico's transfer pricing regime collected 19 billion pesos ($980 million) from large businesses last year, part of a trend that has seen the country's transfer pricing revenue more than triple over the past five years compared with the prior five-year period, its tax administration said.
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May 28, 2025
One Convicted For Role In €195M VAT Fraud Scheme
A Munich court convicted a man for his role in a value-added tax fraud scheme that spanned 17 countries and caused an estimated €195 million ($220 million) in damages, the European Public Prosecutor's Office said Wednesday.
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May 28, 2025
Fried Frank Adds KPMG International Tax Ace In NY
Fried Frank Harris Shriver & Jacobson LLP has hired a KPMG international tax group principal as a tax partner in New York.
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May 28, 2025
EU Proposes Simplified Tax Rules For Remote Workers
The European Commission set out proposals Wednesday to simplify tax rules for remote employees and cross-border work arrangements in a policy paper, as part of a regime to remove barriers for businesses across the European Union.
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May 28, 2025
Hong Kong Adopts OECD's Global Minimum Tax
Hong Kong's government has implemented the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities, expecting it to soon generate HK$15 billion ($1.9 billion) annually, its Inland Revenue Department said Wednesday.
Expert Analysis
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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.
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Impact Of Corporate Transparency Act Ambiguity On Banks
Even though banks generally needn't file beneficial ownership information reports, financial institutions must continue to monitor the status of the Corporate Transparency Act and understand its requirements in case the nationwide injunction that was issued against the CTA earlier this month is overturned, say attorneys at Armstrong Teasdale.
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6 Changes I Would Make If I Ran A Law School
Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.
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Firms Still Have The Edge In Lateral Hiring, But Buyer Beware
Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.
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Think Like A Lawyer: 1 Type Of Case Complexity Stands Out
In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.
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Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity
Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.