International
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October 23, 2025
Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion
Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.
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October 23, 2025
Ex-Clifford Chance Pro Hit With £8M Libel Claim By Barrister
A barrister has sued legal commentator Dan Neidle and his think tank for £8 million ($10.6 million), accusing the former Clifford Chance partner of engaging in a vendetta against him, according to court filings that have now been made public.
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October 22, 2025
Australia Issues Guidance For Minimum Tax Safe Harbor
Australia released guidance Wednesday detailing when companies can forgo detailed top-up tax calculations for a jurisdiction under a safe harbor for the 15% global minimum tax that is based on country-by-country reporting.
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October 22, 2025
US Among Few Places With Amount B Rules, OECD Reports
The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.
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October 22, 2025
'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says
Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.
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October 22, 2025
Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling
Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.
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October 22, 2025
Trade Court OKs $235K Tax Bill On Korean Soju Imports
South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.
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October 22, 2025
Canada Tax Agency Could Expand Audit Powers, Pro Says
Tax attorneys in Canada are closely watching a proposal that would give the country's revenue agency extensive audit powers, including the ability to take information under oath before any potential litigation begins, a practitioner said Wednesday.
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October 22, 2025
Switzerland Seeks Comments On Updated EU Tax Data Deal
The Swiss government is inviting public comments on an agreement it reached with the European Union to update the jurisdictions' agreement for the automatic exchange of tax information, it said Wednesday.
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October 21, 2025
Discovery Against Gem Company Halted In Malawi's Tax Probe
Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.
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October 21, 2025
'Revenge Tax' May Reappear If Pillar 2 Talks Stall, Pros Say
Republican lawmakers are likely to revive what is commonly known as the revenge tax if countries are unable to flesh out a tentative agreement to effectively exempt U.S. companies from the 15% global corporate minimum tax regime known as Pillar Two, practitioners said Tuesday.
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October 21, 2025
EU To Ditch Plans For Transaction Tax, Shell Co. Law
The European Commission plans to withdraw proposed directives that would impose a financial transaction tax and target tax evasion through the use of shell companies, it said Tuesday in a work program for 2026.
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October 21, 2025
Medtronic Says 8th Circ. Wrongly Tossed Tax Court's Method
The Eighth Circuit's rejection of the U.S. Tax Court's latest ruling on the pricing of Medtronic intangibles placed unnecessary restrictions on the court's unspecified method addressing such assets transferred to Puerto Rico, the company argued as it asked the circuit court to rethink its decision.
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October 21, 2025
UK Pensions Body Calls For Long-Term Tax Policy
The government must commit to long-term policy on pension tax relief, an influential trade body said Tuesday, warning that mounting uncertainty every year around the Budget was harming consumer confidence.
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October 20, 2025
G7 Deal Exempting US From Min. Tax Hurts Brazil, Prof Says
Latin American countries, especially Brazil, are concerned that the deal announced by the Group of Seven countries in June exempting U.S. multinationals from a globally agreed 15% minimum tax gives the U.S. an unfair advantage over them, a professor at University of Antwerp said Monday.
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October 20, 2025
Emergency Tariffs Unlawfully Unprecedented, Justices Told
The International Emergency Economic Powers Act has never been used until President Donald Trump to impose tariffs, and nowhere does the law provide that explicit authority, a dozen states, several small businesses and a pair of Illinois toymakers told the U.S. Supreme Court Monday.
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October 20, 2025
Switzerland, EU Sign Automatic Tax Data Exchange Deal
The Swiss government signed an agreement with the European Union to improve its automatic exchange of financial information standards, according to a statement published Monday.
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October 20, 2025
Brazil Signs OECD Convention On Tax Treaties
Brazil on Monday signed the Organization for Economic Cooperation and Development's convention to align bilateral tax treaties with standards aimed at preventing base erosion and profit shifting, according to the organization.
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October 20, 2025
Treasury Floats Plan To Scrap Look-Through Rules
The U.S. Treasury Department proposed regulations Monday that would remove rules that allow revenue officials to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.
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October 20, 2025
China To Offer 50% VAT Rebate For Offshore Wind Electricity
China will offer a 50% rebate on value-added taxes for companies that sell electricity they produce with offshore wind installments starting next month, the State Tax Administration said.
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October 20, 2025
Directors Jailed For £20M Fraud Involving Fake VAT Claims
Six company directors were sentenced Monday for their role in a £20 million ($27 million) tax fraud involving a wholesale electrical appliance business that deliberately understated how much value-added tax was owed to HM Revenue and Customs.
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October 17, 2025
Trump Orders Truck Tariffs, Expands Auto Rebate Program
President Donald Trump signed an executive order Friday to begin anticipated tariffs on heavy and medium trucks on Nov. 1, while expanding a program that domestic auto manufacturers are already utilizing for rebates to existing tariffs on auto vehicles.
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October 17, 2025
Electronic Co. Tells Justices Trump Tariffs Are The Emergency
Emergency tariffs imposed by President Donald Trump are creating extraordinary economic threats under a law that was intended to protect U.S. retailers from such harm, a Virginia-based electronics company told the U.S. Supreme Court on Friday.
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October 17, 2025
UN Shipping Agency Delays Carbon Price Opposed By US
The United Nations' shipping agency agreed Friday to postpone for one year its plan to introduce a global carbon price, which the U.S. government opposes, having called it a "global carbon tax."
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October 17, 2025
Covington Adds Former IRS Special Counsel In DC
Covington & Burling LLP has grown its tax practice in Washington, D.C., with the addition of a former special counsel in the Office of Chief Counsel at the Internal Revenue Service.
Expert Analysis
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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.
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How Design Thinking Can Help Lawyers Find Purpose In Work
Lawyers everywhere are feeling overwhelmed amid mass government layoffs, increasing political instability and a justice system stretched to its limits — but a design-thinking framework can help attorneys navigate this uncertainty and find meaning in their work, say law professors at the University of Michigan.
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The Pros And Cons Of A 2nd Trump Term For UK Tech Sector
While U.S. President Donald Trump’s protectionist stance on trade could disrupt global supply chains on which many U.K. tech firms are reliant, anticipated deregulation could provide fertile ground for investment and growth, and the U.K. tech sector is bracing for a mix of opportunities, say lawyers at Shoosmiths.
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Corp. Transparency Act's Future Under Treasury's Bessent
The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.
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A Look At A Possible Corporate Transparency Act Exemption
Attorneys at Kirkland offer a deep dive into the application of the Corporate Transparency Act's reporting requirements specifically to U.S.-domiciled co-issuers in typical collateralized loan obligation transactions, and consider whether such issuers may be able to assert an exemption from the CTA's reporting requirements.
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Inconsistent Injury-In-Fact Rules Hinder Federal Practice
A recent Third Circuit decision, contradicting a previous ruling about whether consumers of contaminated products have suffered an injury in fact, illustrates the deep confusion this U.S. Supreme Court standard creates among federal judges and practitioners, who deserve a simpler method of determining which cases have federal standing, says Eric Dwoskin at Dwoskin Wasdin.