International
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August 08, 2025
Taxation With Representation: Latham, Alston & Bird, Orrick
In this week's Taxation With Representation, fiber optic connector systems maker Amphenol Corp. buys CommScope's connectivity and cable solutions business, Blackstone acquires Enverus from private equity firms, investors buy a majority stake in medical device company HistoSonics Inc., and ESPN swaps an equity stake for the National Football League's NFL Network and other intellectual property.
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August 08, 2025
Germany Seeks Comments On Amendments To Minimum Tax
Germany is looking for comments on amendments to its 15% minimum tax, including on changes to how deferred tax assets are treated and on the elimination of an anti-avoidance rule limiting deductions for licensing expenses, the Finance Ministry said Friday.
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August 08, 2025
Midyear Review: A Look At The Tax Trends Shaping 2025
Tax professionals had a lot to keep up with in the first half of 2025, from congressional action to extend the 2017 GOP tax overhaul to a tumultuous international trade scene. And the back half of the year is poised to be just as busy, with litigation over how the IRS handles employee retention tax credits, an Amazon suit in South Carolina over sales tax, and an uncertain future for global minimum tax rules. Here, dive into our slate of analysis pieces to help guide you through evolving tax litigation and policy.
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August 07, 2025
Toyota Forecasts $9.5B Annual Hit From US Tariffs
U.S. tariffs would cost Toyota Motor Corp. 1.4 trillion yen ($9.5 billion) during its fiscal year ending March 2026, including 450 billion yen in its first quarter, the automaker said Thursday.
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August 07, 2025
Siemens Contests Nix Of $315M Foreign-Dividend Tax Break
Regulatory missteps caused the IRS to wrongly slash $315 million from a foreign-dividend tax deduction Siemens claimed on shareholder payments it received from an overseas affiliate, the medical giant told the U.S. Tax Court.
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August 07, 2025
Switzerland Says 39% Tariff Hits Over Half Of Exports To US
More than half of Switzerland's exports to the United States are now impacted by a 39% tariff, the Swiss government said Thursday after the country's president left Washington, D.C., pledging to continue negotiations to reduce the rate.
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August 07, 2025
Hodgson Russ Adds Former NY Tax Pros To SALT Group
Hodgson Russ LLP has announced that two former New York state and city tax professionals have joined the firm's state and local tax practice in New York City, advising the team on complex regional tax issues.
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August 07, 2025
India, Russia Sign Trade Pact As US Hits India For Buying Oil
India and Russia agreed to deepen their economic ties the same day the United States set into motion tariffs on India for purchasing Russian oil, the Indian government announced.
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August 07, 2025
HMRC Aims To Improve Data Access For Tax Research
HM Revenue & Customs could achieve its goal of making tax data more easily accessible to other government bodies and external researchers in part by improving its existing anonymized data production service, the agency said Thursday.
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August 07, 2025
Fuel Tax Decline Hit Australia's Coffers, Budget Report Says
The Australian government's budget is expected to have returned to a deficit this year, in part due to the decarbonization of the transportation industry, which has eroded the fuel excise tax base, according to a government report published Thursday.
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August 07, 2025
German Carmakers Press EU To Secure Tariff Relief Quickly
A German automaker association urged the European Union to finalize its trade deal with the U.S. to relieve the car manufacturing industry of the pressure of tariffs.
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August 07, 2025
Accounting Co. Faces Trial In 1st FTP Tax Evasion Case
Accounting firm Bennett Verby Ltd. faced accusations on Thursday that it had failed to prevent tax evasion alongside six individuals charged with tax evasion and fraud offenses.
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August 07, 2025
Judge Extends Freeze On Assets Of Former EY Exec's Wife
A freezing order against the assets of the wife of EY's former head of tax was maintained on Thursday by a court, following a finding that his transfer of his assets to her was a sham designed to hide them from his creditors.
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August 06, 2025
Gov'ts Seek Wider Taxing Rights Pledge In UN Tax Convention
A wide group of countries advocated Wednesday for a de-emphasis on business activities in favor of targeting economic activities in general as governments debated how to articulate a commitment to a "fair allocation of taxing rights" within the United Nations' global tax convention.
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August 06, 2025
Biz Group Urges EU To Pursue Digital Tax, Limit Min. Tax
The European Union should pursue a blocwide digital services tax as a counterbalance to its trade agreement with the U.S. and should limit the 15% minimum tax to preserve investment, an Italian business group said, calling the trade deal "appalling."
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August 06, 2025
Trump Hits India With 50% Tariff For Russian Oil Purchases
President Donald Trump announced Wednesday that he would increase India's tariff rate to 50% by late August, citing the country's imports of Russian oil.
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August 06, 2025
Troutman Adds Former Fannie Mae Associate GC In DC
The former associate general counsel at the Federal National Mortgage Association, who spent the past decade as a tax partner with Morris Manning & Martin LLP, has joined Troutman Pepper Locke LLP in the nation's capital, the firm announced Wednesday.
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August 06, 2025
Starmer Declines To Rule Out Tax Hikes In UK Budget
U.K. Prime Minister Keir Starmer declined to rule out tax hikes in the autumn budget after a think tank claimed Wednesday that the government will need to raise more tax revenue to meet its fiscal rules and prevent a deficit of £41.2 billion ($55 billion).
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August 06, 2025
G7's Tax Carveout For US Cos. Raises EU State Aid Questions
The Group of Seven nations' deal to exclude U.S. companies from Pillar Two minimum tax rules would give those companies a competitive advantage, experts say, prompting questions about the carveout's compatibility with EU state aid rules and whether a viable path exists to challenge the deal.
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August 06, 2025
3 Key Foreign Entity Issues In Claiming Clean Energy Credits
Stricter foreign supply chain and business ownership rules were tacked onto clean energy tax credits that weren't eliminated under the new budget reconciliation law, raising major compliance hurdles that have practitioners eagerly awaiting implementation rules from the U.S. Treasury Department. Here, Law360 outlines key issues the agencies need to address in coming guidance on restrictions targeting projects linked to foreign entities of concern.
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August 06, 2025
Japan, Ukraine Update Tax Treaty Rates, Avoidance Rule
Japan and Ukraine have updated their tax treaty with lower withholding rates for certain shareholders, an anti-avoidance rule and a new time frame used to determine a tax exemption for short-term visitors, the Japanese tax authority said Wednesday.
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August 05, 2025
EU Looks To Expand Sectors For Emissions Trading State Aid
The European Union is looking to expand sectors that are eligible to receive state aid to compensate for increased costs of operation from complying with the bloc's emissions trading system, as well as updating related benchmarks for electricity consumption efficiency, according to a consultation.
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August 05, 2025
McGuireWoods Adds Loeb & Loeb Tax Pro In Los Angeles
McGuireWoods LLP is enhancing its corporate team, announcing Tuesday it is bringing in a Loeb & Loeb LLP tax expert as a partner in its Los Angeles office in Century City.
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August 05, 2025
Simpson Thacher Adds Tax, Funds Pro From Dechert
Simpson Thacher & Bartlett LLP announced Monday that it has continued its growth in the tax and registered funds spaces, welcoming a partner from Dechert LLP to its New York office.
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August 05, 2025
Gov'ts Aim For Broad Pledges To Form UN Tax Convention
Diplomats broadly agreed Tuesday to draft high-level commitments for the U.N. global tax convention and leave the technical details of how to operationalize those commitments to binding protocols that would supplement the convention.
Expert Analysis
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AbbVie Frees Taxpayers From M&A Capital Loss Limitations
The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.
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ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'
The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.
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Can Companies Add Tariffs Back To Earnings Calculations?
With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.
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A Look At DOJ's Dropped Case Against Early Crypto Operator
The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.
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8 Ways Lawyers Can Protect The Rule Of Law In Their Work
Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.
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Law School's Missed Lessons: Communicating With Clients
Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.
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Navigating Antitrust Risks When Responding To Tariffs
Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.
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Key Points From HMRC's Tax Reform Proposals
Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.
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Adapting To Private Practice: From US Rep. To Boutique Firm
My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.
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IRS Should Work With Industry On Microcaptive Regs
The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.
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What To Note As UK Adopts OECD Crypto Disclosure Rules
With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.
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Senate's 41% Litigation Finance Tax Would Hurt Legal System
The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.