International
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September 29, 2025
IRS Pulls Plug On Proposed Corporate Spinoff Regulations
Proposed regulations for a narrow set of tax-free corporate separation deals known as spinoffs and a multiyear reporting regime for those transactions will be withdrawn, the Internal Revenue Service announced Monday, citing widespread criticism of the framework proposed in January.
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September 29, 2025
IRS Cancels Hearing On Offshore Profit Regulations
The Internal Revenue Service said Monday that it has canceled a public hearing on proposed rules that would require U.S. multinational corporations to create annual shareholder accounts and follow new pooling concepts to account for previously taxed foreign earnings and basis adjustments.
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September 26, 2025
Audits Focused On Profit Shifting, Transfer Pricing, ATO Says
International profit shifting is the subject of about 70% of the Australian Taxation Office's ongoing income tax audits of public and multinational corporations, with transfer pricing of cross-border financing and marketing being major focuses, according to a report published Friday.
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September 26, 2025
Trump Announces 100% Tariff On Drug Imports Starting Oct. 1
President Donald Trump announced a slew of new Section 232 tariffs to be imposed beginning Oct. 1, including a 100% tariff on drug imports and new rates for semi trucks, kitchen cabinets, bathroom vanities and upholstered furniture.
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September 26, 2025
Microsemi, IRS Reach Deal To Settle Transfer Pricing Dispute
The Internal Revenue Service has reached a settlement with semiconductor manufacturer Microsemi to resolve the agency's transfer pricing adjustment regarding an intercompany purchase of semiconductor products, according to U.S. Tax Court filings.
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September 26, 2025
Taxation With Representation: De Brauw, Hengeler Mueller
In this week's Taxation With Representation, power grid operator TenneT Holding sells a stake in its German transmission business to institutional investors, Pfizer Inc. acquires biotechnology company Metsera Inc., and Dutch brewer Heineken NV buys most of Costa Rica's FIFCO beverage and retail operations.
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September 25, 2025
Perrigo Mostly Beats US In $163M Tax Refund Dispute
A Michigan federal court largely sided Thursday with pharmaceutical company Perrigo in a $163 million tax refund case, rejecting the government's claim that the company's transactions with a foreign entity lacked economic substance and were meant only to avoid taxes.
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September 25, 2025
Finland Plans To Raise Taxes On Soft Drinks, Mined Minerals
The Finnish government will increase its soft drink tax based on different levels of sugar content, while also nearly quadrupling its mining mineral tax, the Ministry of Finance announced Thursday.
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September 25, 2025
EU, US Trade Officials Meeting On Tariff Deal
In advance of a meeting Thursday between European and U.S. trade officials, European Commission trade spokesman said discussion topics could include possible rate reductions and tariff exemptions for additional goods under an evolving bilateral framework trade agreement.
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September 25, 2025
Philippine Airlines Challenges $7.1M IRS Bill In Tax Court
Philippine Airlines is disputing $7.1 million in income taxes assessed by the IRS, claiming the agency erred by determining that the airline's gross transportation income was not exempt under the U.S.-Philippines tax treaty, according to a petition filed in the U.S. Tax Court.
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September 25, 2025
Fed. Circ. Upholds China Tariffs From Trump's 1st Term
The Federal Circuit on Thursday blessed a large batch of tariffs on Chinese goods installed by President Donald Trump during his first White House term, turning away a host of importers' claims that the levies had been imposed illegally.
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September 25, 2025
Gov't Warns Of Tax Hit From Pre-Budget Pension Withdrawals
British pension savers that pull cash out of their retirement pots due to pre-Budget jitters will eat into a portion of their tax-free allowance, even if they later change their mind and cancel the withdrawal, the government confirmed Thursday.
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September 25, 2025
Fladgate Says Founders Of Claims Biz Pocketed Tax Refunds
Fladgate LLP has told a London court that the founders of a claims management company swindled tax credits linked to the firm's work on group litigation involving property search companies.
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September 24, 2025
Execs Breached Danish Deal In $2B Tax Case, Court Says
Three men claiming to be pension plan executives who struck a civil settlement with the Danish taxing authority over their role in a $2 billion tax fraud scheme breached their settlement agreement, a New York federal court found, saying the men had not paid back the amount they promised.
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September 24, 2025
Ill. Justices Won't Hear Pepsi's $2.1M Tax Penalty Case
An Illinois appeals court decision allowing $2.1 million in penalties against PepsiCo for categorizing Frito-Lay expatriates' compensation as foreign payroll will stand, as the state's highest court declined to review the dispute Wednesday.
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September 24, 2025
EU Committee Adopts Economic Presence Rules For Biz Tax
Multinational companies with revenues above €1 million ($1.17 million) from a European Union country would be deemed to have a permanent establishment subject to taxation there under amendments that a European Parliament committee incorporated into a proposed corporate tax base directive Wednesday.
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September 24, 2025
Senate Finance Panel To Hold Digital Assets Taxation Hearing
The Senate Finance Committee will hold a hearing with digital asset experts on Oct. 1 to examine the tax treatment of income derived from such assets, Committee Chairman Mike Crapo, R-Idaho, announced Wednesday.
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September 24, 2025
EU Commission Provides Guidance For Blocwide VAT Rules
The European Commission issued guidance Wednesday to help European Union member states enact blocwide value-added tax rules for the digital economy, including real-time e-invoicing on cross-border transactions.
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September 24, 2025
Hotel Boss Banned From Directorship Over £1.6M Tax Debt
The former boss of a hotel on the Isle of Skye has been banned as a company director over tax debts totaling around £1.6 million ($2.2 million) to Britain's revenue authority, the U.K.'s insolvency agency said Wednesday.
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September 23, 2025
Trump Tariffs Are Constitutional, President's Allies Tell Justices
Two Republican lawmakers and two allied nonprofit groups told the U.S. Supreme Court on Tuesday that it should allow President Donald Trump's emergency tariffs authorized under the International Emergency Economic Powers Act.
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September 23, 2025
EU Eyeing Country-Level Min. Tax Exemption For US Cos.
The European Union's preferred method for accommodating the U.S. proposal to exempt American companies from the 15% global minimum tax's international provisions would be to allow a conditional safe harbor that member countries would need to enact individually, a top EU tax official told lawmakers Tuesday.
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September 23, 2025
Albania Becomes 10th To Sign Min. Tax Payments Treaty
Albania became the 10th country to sign a multilateral treaty aimed at carrying out a 9% minimum tax on income sent from signatory jurisdictions to low-taxed entities within a corporate group, the Organization for Economic Cooperation and Development said Tuesday.
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September 23, 2025
Full Effects Of US Tariffs 'Yet To Be Felt,' OECD Report Says
Economic growth in the U.S. is expected to dip in 2026 partly because of global trade tensions, the full effects of which "have yet to be felt," the Organization for Economic Cooperation and Development reported Tuesday.
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September 23, 2025
UBS Settles Long Tax Dispute With France For An €835M Fine
UBS has resolved its long-running tax dispute with France over cross-border transactions, agreeing to pay a fine of €835 million ($985 million), the company said Tuesday.
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September 22, 2025
The Tax Angle: Green Energy Permits, Enhanced ACA Credits
From a look at permitting delays holding up solar and wind tax credit projects to uncertainty surrounding the renewal of Affordable Care Act enhanced premium tax credits, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
Expert Analysis
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.
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What's Next For Russia Sanctions After Task Force Disbanded
Attorney General Pam Bondi’s recent disbanding of Task Force KleptoCapture, which was initially aimed at seizing Russian oligarchs’ funds and assets, is unlikely to mean the end of Russia sanctions enforcement and other economic countermeasures, as the architecture for criminal enforcement remains in place, say attorneys at BakerHostetler.
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How Law Firms Can Counteract The Loneliness Epidemic
The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.
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5 Keys To Building Stronger Attorney-Client Relationships
Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.
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Attorneys Must Act Now To Protect Judicial Independence
Given the Trump administration's recent moves threatening the independence of the judiciary, including efforts to impeach judges who ruled against executive actions, lawyers must protect the rule of law and resist attempts to dilute the judicial branch’s authority, says attorney Bhavleen Sabharwal.
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Rethinking 'No Comment' For Clients Facing Public Crises
“No comment” is no longer a cost-free or even a viable public communications strategy for companies in crisis, and counsel must tailor their guidance based on a variety of competing factors to help clients emerge successfully, says Robert Bowers at Moore & Van Allen.
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Reading The Tea Leaves On Mexico, Canada And China Tariffs
It's still unclear whether the delay in the imposition of U.S. tariffs on Canadian and Mexican imports will result in negotiated resolutions or a full-on trade war, but the outcome may hinge on continuing negotiations and the Trump administration's possible plans for tariff revenues, say attorneys at Eversheds Sutherland.