International
-
November 07, 2025
Eaton Should Have Weighed Borrowing In Europe, Judge Says
When it acquired Ireland-based Cooper Industries in 2012, Eaton Corp. should have considered the costs of borrowing in Europe to finance the transaction, Tax Court Judge Albert Lauber said Friday in questioning a former Eaton official.
-
November 07, 2025
Justices Cast Constitutional Clouds Over Trump's Tariffs
Several U.S. Supreme Court justices appeared skeptical of the government's arguments seeking to salvage President Donald Trump's emergency tariffs, signaling that the high court may come down with a ruling that reinforces Congress' constitutional authority to impose tariffs.
-
November 07, 2025
Romania Seeks Comments On Forms For Minimum Tax
Romania's tax authority asked for feedback Friday on a form for submitting tax liabilities under the 15% global minimum and a notice for declaring an obligation to submit the tax liability form.
-
November 07, 2025
Latin American Tax Revenues Remain Low, OECD Says
The average ratio of tax revenue to gross domestic product in the Latin American and Caribbean region was 21.3% in 2023, the OECD said in a report published Friday that partly attributed the relatively low number to ineffective tax incentives.
-
November 07, 2025
Taxation With Representation: Kirkland, Cravath, Paul Weiss
In this week's Taxation With Representation, consumer products giant Kimberly-Clark acquires Tylenol maker Kenvue, shale producers SM Energy and Civitas Resources announce a merger, and power management company Eaton buys Boyd Corp.'s thermal business.
-
November 07, 2025
UK Lawmakers Call For Stronger Taxation Of Online Gambling
The U.K. government should ensure online gambling businesses always pay a higher tax rate than traditional casinos, a parliamentary committee said in report Friday, adding that anti-avoidance measures may be needed to target gambling companies' use of offshore tax havens.
-
November 07, 2025
Kazakhstan's VAT On Foreign Online Platforms Raises $226M
Kazakhstan's value-added tax on digital services has brought in 118.4 billion tenge ($226 million) from global online platforms since its enactment in 2022, the country's Ministry of Finance said.
-
November 06, 2025
Fossil Fuel Industry Wants Broader Suing Powers In USMCA
Oil and gas industry groups have asked the Office of the U.S. Trade Representative to broaden the ability of foreign investors to sue governments in the U.S.-Mexico-Canada Agreement during an upcoming joint review.
-
November 06, 2025
EU Authorities Probe Suspected €61.5M VAT Fraud Ring
European Union authorities carried out search and seizure operations Thursday in Austria as part of an investigation into a suspected cross-border value-added-tax fraud scheme that has purportedly resulted in an estimated total of €61.5 million ($71 million) in unpaid taxes.
-
November 06, 2025
IRS Microcaptive Reporting Rules Suit Can Move Forward
A global tax services provider can move forward with its suit against the IRS to vacate tax reporting rules for microcaptive insurance companies, a Texas federal court said, finding the company had a stake in the challenge and a right to bring the case.
-
November 06, 2025
Brazil's Senate Approves Tax Breaks For Low-Income Earners
The upper house of Brazil's National Congress voted Thursday to approve income tax breaks for those earning up to 7,350 Brazilian real ($1,373) a month, while creating a progressive tax rate for high-income earners.
-
November 06, 2025
Finland Proposes Anti-Avoidance Measure For Minimum Tax
Finland began seeking feedback Thursday on amendments to the country's 15% global minimum tax that include a new anti-avoidance provision but primarily incorporate OECD guidance.
-
November 06, 2025
UK Pensions Body Warns Gov't Over Removing Tax Breaks
Millions of workers could lose out on hundreds of pounds a year if the government moves to end tax breaks on pension contributions, a trade body said Thursday in a stark warning to policymakers.
-
November 06, 2025
German Watchdog Fines JP Morgan €45M For AML Failures
German financial regulator BaFin said Thursday it has hit pan-European bank JP Morgan SE in Frankfurt with its largest-ever fine of €45 million ($52 million) for breaching anti-money-laundering rules.
-
November 05, 2025
Judge Questions Transfer Of Eaton's $14B Foreign Asset
A U.S. Tax Court judge questioned a former Eaton Corp. official Wednesday about the company's decision to restructure the ownership of a valuable foreign subsidiary when it inverted in 2012, noting that the move placed a $14 billion asset out of the U.S. company's reach.
-
November 05, 2025
Docs Show IRS Improperly Shared Data With ICE, Groups Say
Documents submitted by the U.S. government to a D.C. federal court show the IRS violated taxpayer privacy laws by sharing individuals' addresses with ICE despite its requests lacking required information and by accepting an unreasonable explanation about why the information was requested, several groups said.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
Expert Analysis
-
How Attys Can Use AI To Surface Narratives In E-Discovery
E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.
-
AbbVie Frees Taxpayers From M&A Capital Loss Limitations
The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.
-
ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'
The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.
-
Can Companies Add Tariffs Back To Earnings Calculations?
With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.
-
A Look At DOJ's Dropped Case Against Early Crypto Operator
The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.
-
8 Ways Lawyers Can Protect The Rule Of Law In Their Work
Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.
-
Law School's Missed Lessons: Communicating With Clients
Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.
-
Navigating Antitrust Risks When Responding To Tariffs
Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.
-
Key Points From HMRC's Tax Reform Proposals
Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.
-
Adapting To Private Practice: From US Rep. To Boutique Firm
My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.
-
IRS Should Work With Industry On Microcaptive Regs
The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.
-
What To Note As UK Adopts OECD Crypto Disclosure Rules
With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.
-
Senate's 41% Litigation Finance Tax Would Hurt Legal System
The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.