International
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November 14, 2025
Liquidated Captive Insurer Fights IRS Bill In Tax Court
A captive insurance company that was later dissolved challenged $800,000 in taxes and penalties in the U.S. Tax Court, saying the Internal Revenue Service wrongly claimed the company had $3 million in unreported long-term capital gains.
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November 14, 2025
US Expatriations Rise To 1,600 In 3rd Quarter, IRS Says
The number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter, the IRS said Friday.
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November 14, 2025
HMRC Warns Against New Payroll Tax Credit Fraud Scheme
HM Revenue & Customs has flagged an emerging trend where organized crime groups market fraudulent payroll services to U.K. companies by falsely claiming they can offset employment taxes by using tax credits from a third-party business, the agency said Friday.
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November 14, 2025
EU To Boost Cooperation Among Enforcers To Fight Tax Fraud
The European Union pledged on Friday to bolster its fight against massive tax fraud that costs approximately €89 billion ($103 billion) across the bloc each year by rolling out a plan to deepen cross-border cooperation.
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November 14, 2025
Denmark Has Until Dec. 12 To Appeal £1.4B Cum-Ex Defeat
Denmark has 28 days to try to revive its £1.4 billion ($1.8 billion) case over a tax fraud allegedly orchestrated by convicted hedge fund trader Sanjay Shah, a judge said Friday as he gave full reasons for refusing permission to appeal.
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November 13, 2025
Eaton Witnesses Probed About Data Used For Credit Analysis
An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.
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November 13, 2025
Latin American Trade Deals With US Include Zero Tariff Rates
Latin American countries including El Salvador, Guatemala, Ecuador and Argentina committed to nontariff reductions for U.S. producers in exchange for a zero tariff rate on many imports not readily available in the U.S., under details of framework trade agreements the White House unveiled Thursday.
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November 13, 2025
High Court's Tariff Ruling May Trigger Refunds, Reimposition
Importers are being advised to prepare for potential refunds in the event the U.S. Supreme Court rules President Donald Trump's emergency tariffs are unlawful, leaving questions about how a refund process might play out and whether the duties would be reimposed.
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November 13, 2025
Divided EU Places Energy Tax Overhaul On Back Burner
European Union finance ministers were divided Thursday over whether a proposed overhaul to energy taxation fell short of enough ambition to achieve climate goals or was too costly for the bloc's competitiveness, leading to an indefinite delay of the legislation.
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November 13, 2025
Fuel Excise Tax Is Most Used Carbon Measure, OECD Says
Fuel excise taxes are the most common measure aimed at curbing greenhouse gas emissions, according to a report released Thursday by the Organization for Economic Cooperation and Development, which noted that these provisions covered 24% of 79 countries' emissions in 2023.
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November 13, 2025
MVP: Kirkland's Adam Kool
Adam Kool, a tax partner at Kirkland & Ellis LLP, spent the past year advising on high-profile, industry-transforming transactions. Kool's work on AbbVie's $63 billion acquisition of the pharmaceutical giant Allergan, GTCR's pending $24.25 billion sale of global payment processing company Worldpay and other billion-dollar transactions has earned him a spot as one of the 2025 Law360 Tax MVPs.
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November 13, 2025
ECJ Rules VAT Exemption Can't Hinge On Missing Documents
European Union member states cannot deny value-added tax exemptions solely due to improperly filed paperwork if companies can still prove that they sold cross-border goods within the bloc, the EU's top court ruled Thursday.
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November 13, 2025
Businessman Too Late To Challenge £5M Tax Evasion Penalty
A businessman's attempt to challenge a civil value-added tax evasion penalty of almost £5 million ($6.6 million) was refused because it was launched in breach of the time limit for appeals, a London tribunal ruled.
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November 13, 2025
Marine Co. Can't Get Madeira Tax Benefits, Top EU Court Says
A marine services company must repay corporate tax benefits it received in Madeira because the Portuguese authorities can't verify the jobs it created as part of claiming state aid, the European Union's top court ruled Thursday.
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November 13, 2025
Shein Wins Stay On £5.8M Tax Fraud Case Pending Arbitration
Fashion retailer Shein won a bid on Thursday to stay a £5.8 million ($7.7 million) tax fraud case brought by a U.K. customs clearance company, ahead of arbitration proceedings in which Shein is fighting to recover £1.5 million.
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November 13, 2025
In-House Tax Controversy Director Joins Miller & Chevalier
The former director of tax controversy at Cleveland, Ohio-based real estate company GBX Group LLC has moved to Miller & Chevalier Chtd.'s Washington, D.C., office, where she'll continue working on a range of tax-related matters.
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November 13, 2025
Insurance Lobby Pushes Back On Rumored Budget Changes
The government risks undermining the financial security of millions if it pushes ahead with rumored changes to pension tax relief in the budget, an insurance trade body warned Thursday.
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November 12, 2025
Ports Warn USTR Against China Ship Fees, Crane Tariffs
The U.S. Trade Representative should reconsider tariffs on Chinese cranes and fees on Chinese and other foreign ships while those measures are suspended for the next year as part of a trade truce between China and the U.S., according to comments recently submitted by a U.S. port industry association.
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November 12, 2025
Doctor Owes Penalties Over Microcaptives, Tax Court Affirms
The U.S. Tax Court on Wednesday affirmed economic substance and accuracy-related penalties pinned on an eye doctor and his wife over their microcaptive insurance arrangement.
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November 12, 2025
Gov'ts Call For Shared Definition Of Harmful Tax Practices
Governments called Wednesday for a shared definition of harmful tax practices as they weighed which commitments to make on the topic within the United Nations tax convention.
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November 12, 2025
Finnish Income Tax Revenue Rises Despite Corp. Tax Decline
Finland's income tax revenue increased overall last year despite a drop in corporate tax receipts, the country's tax administration announced.
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November 12, 2025
MVP: Eversheds Sutherland's Maria Todorova
Eversheds Sutherland's Maria Todorova secured a pivotal win for Duke Energy by successfully arguing that South Carolina's investment tax credit statute allowed the company to claim $20 million for qualifying investments, earning her a spot as one of the 2025 Law360 Tax MVPs.
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November 12, 2025
DOJ Fights Claim That IRS Unlawfully Shared Info With ICE
The Trump administration has said the IRS complied with regulations when considering information requests from immigration enforcement officials, urging a D.C. federal judge to deny advocacy groups' request to submit a supplemental filing asserting that documents it turned over show otherwise.
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November 12, 2025
Virgin Islands Gives 90-Day Tax Amnesty For Storm Recovery
The U.S. Virgin Islands established a 90-day amnesty period to waive penalties for overdue property, income and gross receipts taxes to help residents and businesses recovering from Hurricanes Irma and Maria and Tropical Storm Ernesto under a bill signed by the governor.
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November 12, 2025
Importer's Appeal Over £7.8M VAT, Customs Bill Dismissed
A Brighton tribunal dismissed a textiles importer's appeal against the U.K. tax authority's finding of a combined value-added tax and customs liability of £7.8 million ($10.2 million), saying there was a lack of evidence to support its claim to tax relief.
Expert Analysis
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Replacing The Stigma Of Menopause With Law Firm Support
A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.
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Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.
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Law Firms Should Move From Reactive To Proactive Marketing
Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.
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The Big Issues A BigLaw Associates' Union Could Address
A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.
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It's Time For A BigLaw Associates' Union
As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.
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How Justices Upended The Administrative Procedure Act
In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.
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Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster
Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.
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Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?
A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.
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3 Leadership Practices For A More Supportive Firm Culture
Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.
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E-Discovery Quarterly: Rulings On Hyperlinked Documents
Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.
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Loper Bright Limits Federal Agencies' Ability To Alter Course
The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.
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After Chevron: Delegation Of Authority And Tax Regulators
The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.
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Lawyers Can Take Action To Honor The Voting Rights Act
As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.