International
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November 25, 2025
Profit Shifting Signs Persist Despite Waning, OECD Says
Signs of profit shifting by multinational companies remain persistent despite some abatement over the past several years, the Organization for Economic Cooperation and Development said Tuesday.
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November 25, 2025
4 Things To Watch As UK Releases Budget
The U.K.'s Labour government is set to release an autumn budget Wednesday that faces a test of balancing a pledge not to raise working people's taxes with an expected need to boost revenue to meet fiscal rules. Here are four things to watch for as the budget is issued.
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November 25, 2025
IRS To Propose Regs On Repeal Of CFC Tax Year Deferral
The IRS intends to issue proposed regulations that address the repeal of a provision that allowed a controlled foreign corporation to begin its tax year one month earlier than its majority shareholder in the U.S., the agency said Tuesday.
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November 25, 2025
Half A Million Pensioners 'At Risk Of Paying Income Tax'
An additional half a million state pensioners would pay income tax if the government extends the freeze on thresholds for another two years, a former pensions minister has said.
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November 24, 2025
HMRC Updates Guidance For Digital Tax Filings
HM Revenue & Customs updated guidance Monday for its project to digitalize tax self-assessment, including new guidelines on the digital records regarding income and other information that taxpayers will need to submit.
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November 24, 2025
Malaysia's DST Must Avoid Bias Against US, Minister Says
Malaysia will not impose a digital services tax that discriminates against American companies under its U.S. trade agreement, the country's Minister of Digital told lawmakers Monday, maintaining that this won't restrict the country's sovereignty.
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November 24, 2025
AICPA Urges Allowing Barred Foreign Losses For Use In US
Losses that aren't allowed to reduce tax liabilities abroad should be accepted in the U.S. under rules surrounding dual consolidated losses because they don't cause the dual deductions that those rules aim to prevent, the American Institute of Certified Public Accountants said Monday.
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November 24, 2025
G20 Countries Working To Address Pillar 2 Concerns
Group of 20 nations are negotiating with countries at the Organization for Economic Cooperation and Development to address concerns regarding the 15% global minimum tax agreement known as Pillar Two, G20 leaders announced during their Johannesburg summit.
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November 21, 2025
Judge Halts IRS-ICE Info-Sharing Agreement
A D.C. federal judge temporarily stopped the IRS on Friday from sharing confidential taxpayer addresses with immigration enforcement officials, saying the agency's disclosures of addresses in August under an information-sharing deal were unlawful.
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November 21, 2025
IRS Finalizes Stock Buyback Tax Regs Without 'Funding Rule'
The Internal Revenue Service released final regulations Friday for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule, which would apply the levy to a U.S. subsidiary of a foreign parent company.
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November 21, 2025
Trump Excludes Some Brazilian Foods From Higher Tariffs
President Donald Trump has excluded many Brazilian food products from a 40% tariff, including coffee, cocoa, beef and fruits, after receiving word initial progress has been made in ongoing trade negotiations, according to an executive order.
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November 21, 2025
Key Issues Facing The IRS Amid Looming Budget Cuts
The Internal Revenue Service is facing steep budget cuts in 2026, raising concerns about the agency's ability to handle taxpayer services and enforcement operations that are crucial for bringing in revenue and maintaining compliance with the voluntary system. Here, Law360 looks at the key areas where resource constraints are expected to hamper the IRS and what practitioners can do in response.
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November 21, 2025
UK Inheritance Tax Revenue Up 4% So Far In 2025
The government collected £5.2 billion ($6.8 billion) in inheritance tax between April and October, figures published on Friday by Britain's tax authority show, extending a record-setting trend in the 2025/26 financial year.
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November 20, 2025
Importers Left With Uncertainty After US-China Trade Truce
U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation.
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November 20, 2025
Treasury To Curtail Tax Credits For Unauthorized Immigrants
The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday.
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November 20, 2025
EU Needs Unified Tax Benefits For Electricity, Experts Say
The European Union needs a unified approach to tax benefits that would treat electricity more favorably than fossil fuels amid an impasse surrounding its overhaul to the energy taxation system, experts told the European Parliament's tax committee Thursday.
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November 20, 2025
FBAR Penalty Against Ex-Prof Is Constitutional, Court Says
A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it.
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November 20, 2025
EU Council Approves Tax Deal Changes With 5 States
The Council of the European Union said Thursday that it has approved updates to tax agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland, including new rules to help prevent tax evasion and fraud.
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November 19, 2025
Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real
A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.
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November 19, 2025
Tax Court Upholds Rejection Of Tax Tipster's Award
The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday.
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November 19, 2025
Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty
Governments expressed widespread support for adopting measures to strengthen the mutual agreement procedure within a protocol on dispute resolution in the United Nations tax convention during the latest round of negotiations.
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November 19, 2025
Tax Court Substance Ruling Offers Silver Lining For Taxpayers
Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions.
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November 19, 2025
OECD Releases Model Tax Treaty Updates For Amount B
The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B.
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November 19, 2025
EU Tax Compliance Rules Raise €6.8B Annually, EC Finds
The European Union's directive for administrative cooperation in taxation, known as DAC, has helped tax authorities generate €6.8 billion ($7.8 billion) a year in extra revenue, the European Commission said in a report Wednesday.
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November 19, 2025
Trump's Global Tariffs Curtailed Trade, Data Shows
U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.
Expert Analysis
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When Innovation Overwhelms The Rule Of Law
In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.
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Imagine The Possibilities Of Openly Autistic Lawyering
Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.
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Litigation Funding Disclosure Debate: Strategy Considerations
In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.
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5 Ways To Create Effective Mock Assignments For Associates
In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.
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Mentorship Resolutions For The New Year
Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.
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Tax Directive Marks Milestone In Harmonizing EU System
The Council of the European Union’s recently adopted tax directive is a significant step toward streamlining and modernizing procedures for member states, and will greatly reduce administrative burden and compliance costs for cross-border investors, says Martin Phelan at Simmons & Simmons.
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5 Litigation Funding Trends To Note In 2025
Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.
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Rethinking Litigation Risk And What It Really Means To Win
Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.
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Small Biz Caught In Corporate Transparency Act Crossfire
Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.
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No, Litigation Funders Are Not 'Fleeing' The District Of Del.
A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.
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5 E-Discovery Predictions For 2025 And Beyond
In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.
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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.