International
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December 17, 2025
Court Remands Commerce Ruling On Vietnam Steel Duties
The U.S. Department of Commerce did not properly substantiate its 2023 findings that imports of Vietnamese steel products were flouting duties imposed on South Korea, India and China, the U.S. Court of International Trade said, remanding the agency's determinations.
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December 17, 2025
Ex-Biden Tax Counsel To Chair Willkie Tax Resolution Team
Willkie Farr & Gallagher LLP has hired a former senior tax counsel who worked in two Democratic presidential administrations to come on board as chair of the firm's tax resolution practice group, according to a Wednesday announcement.
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December 17, 2025
EU Looking To Merge Tax Directives Into Single Instrument
The European Commission is considering consolidating the nine bloc directives on administrative taxation cooperation — which cover such areas as the Organization for Economic Cooperation and Development's global minimum tax, crypto-asset reporting and cross-border tax rulings — into one legal instrument.
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December 17, 2025
Treasury Issues Final Rule On BEAT For Securities Lending
Taxpayers must determine and account for certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax, according to a final rule released Wednesday by the U.S. Department of the Treasury.
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December 17, 2025
EU Looks To Expand CBAM To Machinery, Other Products
The European Union has proposed expanding its carbon border adjustment mechanism beyond basic materials to cover certain steel- or aluminum-intensive products like machinery and appliances, saying it wants to prevent spurring emissions-heavy production outside the bloc.
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December 17, 2025
Brazil's New Dividend Tax Rules To Impose 10% Withholding
Dividends and profits paid by Brazilian entities to nonresidents will generally be subject to a 10% withholding tax starting in the new year, the country's revenue agency said in recent guidance, adding that 2025 distributions must be approved before the end of this year to avoid the new tax.
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December 17, 2025
Tax Authorities Shared Data 5,500 Times In 2024, OECD Says
Tax authorities exchanged information on tax rulings 5,500 times last year as part of the base erosion and profit-shifting rules developed by the Organization for Economic Cooperation and Development, according to a report published Wednesday.
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December 17, 2025
UK Supreme Court Tosses Hotel's Atty Fee VAT Appeal
A hotel company can't reclaim value-added tax paid on fees to lawyers and accountants as part of selling a subsidiary to finance the opening of a new hotel, the U.K. Supreme Court ruled Wednesday.
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December 16, 2025
Corporate Transparency Act Is Constitutional, 11th Circ. Says
The Corporate Transparency Act is constitutional because it regulates economic activities with a substantial impact on interstate commerce and doesn't violate protections against unreasonable searches, the Eleventh Circuit said Tuesday, reversing a lower court's decision.
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December 16, 2025
Developing Nations Expand Corporate Tax Breaks, OECD Says
Low- and middle-income countries generally expanded corporate tax incentives in 2024, while some coupled those measures with tax increases, the OECD reported Tuesday.
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December 16, 2025
Fired Top Antitrust Official Warns Of 'Politicization'
The former No. 2 at the U.S. Department of Justice's Antitrust Division until he was terminated this year testified Tuesday about the "politicization" of antitrust enforcement.
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December 17, 2025
CORRECTED: Trade Court Nixes Injunction In Trump Tariff Suit
The U.S. Court of International Trade has denied a preliminary injunction in a suit challenging President Donald Trump's emergency tariffs after auto part retailers failed to convince the court that the relief was necessary to preserve their potential right to refunds.
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December 16, 2025
Morrisons Owes £17M VAT On Chicken Sales, Tribunal Rules
A London tribunal ruled that WM Morrison Supermarkets should have paid £17 million ($22.8 million) value-added tax on rotisserie chickens because the product qualifies as "hot food."
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December 23, 2025
Sullivan & Cromwell Hires Kirkland Pair For London Office
Sullivan & Cromwell LLP said Tuesday that it has hired two new partners from Kirkland & Ellis LLP in London, boosting the firm's private equity and tax capabilities as it continues to expand in the City.
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December 15, 2025
UK Trader Couldn't Have Known Of VAT Fraud, Court Says
Despite its "cavalier approach to due diligence," a scrap metal trader in the U.K. couldn't have known its suppliers were engaged in value-added tax fraud, so it isn't liable for additional tax and penalties, the First-tier Tribunal Tax Chamber said in a decision.
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December 15, 2025
UAE Clarifies Corp. Tax Liability Calculations
The United Arab Emirates has amended its corporate tax law to clarify certain tax liability calculations, including how to factor in credits for withholding and foreign taxes, Abu Dhabi's state news agency said Monday.
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December 15, 2025
Cash Withdrawn From Online Biz Taxable, Tax Court Finds
A man who received no paycheck from the online electronics business he ran in 2012 and 2013 but used its funds to purchase luxury vehicles and help a friend should have reported those amounts as taxable income, the U.S. Tax Court held Monday.
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December 15, 2025
Fed. Court Asked To Block IRS' Microcaptive Reporting Rule
A Texas federal court should vacate an IRS rule aimed at flagging potential tax avoidance by requiring companies to disclose information about their microcaptive insurance transactions because it undermines Congress' authority, according to a Texas plastics company and its microcaptive adviser.
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December 15, 2025
Former Montana Insurer Wants Income Exclusion
A Montana insurance company that dissolved in 2023 is challenging the IRS' determination that transactions it engaged in with an entity on the Turks and Caicos Islands didn't actually involve insurance and therefore aren't deductible for 2021.
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December 15, 2025
MPs Launch Inquiry Into Large Business Tax Compliance
HM Revenue & Customs is facing an inquiry over its handling of tax compliance among large businesses, a parliamentary committee announced.
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December 12, 2025
Judge Says Eaton Moved $14B Subsidiary For Tax Purposes
A U.S. Tax Court judge said Friday that he plans to find Eaton's U.S. group transferred ownership of a $14 billion subsidiary overseas in 2012 solely to justify payment of higher interest rates and guarantee fees to the company's new Irish parent.
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December 12, 2025
DOJ Shake-Up Keeps Criminal Tax Meetings, Ex-Official Says
The U.S. Department of Justice — despite recently eliminating its Tax Division as part of a broad restructuring — continues to meet with practitioners representing clients who may face federal criminal tax charges, the former division chief said Friday.
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December 12, 2025
IRS To Revamp Voluntary Disclosure Program
The Internal Revenue Service will be updating a program early next year that would allow taxpayers to voluntarily report previously undisclosed income as a way to resolve their tax issues to facilitate a simpler reporting process, the agency's criminal enforcement chief said Friday.
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December 12, 2025
Treasury Issues Final Rules For Taxing Foreign Gov't Income
The U.S. Treasury Department issued final regulations Friday for determining whether income of foreign governments derived within the U.S. is taxable along with proposed regulations concerning when a foreign government has effective control of a commercial entity.
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December 12, 2025
Taxation With Representation: Cravath, Skadden, Debevoise
In this week's Taxation With Representation, Paramount Skydance Corp. launches a hostile bid for Warner Bros. Discovery, challenging Netflix's deal to acquire the studio and streaming business, IBM acquires data streaming company Confluent, and natural gas company Antero Resources Corp. expands via a deal with HG Energy.
Expert Analysis
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.