International
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July 30, 2025
OECD Releases Spreadsheets For Min. Tax, Crypto Reporting
The OECD released a blueprint Wednesday for tax authorities to identify errors in tax returns shared by other authorities pursuant to the 15% global minimum tax, along with an updated blueprint for authorities to swap information on cryptocurrency holdings.
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July 30, 2025
UK Gov't Forced To Repay £48.7M In Pension Overtaxation
The government has had to hand back £48.7 million ($64.7 million) in the past three months to Britons who paid too much tax when tapping into their pension savings, figures revealed Wednesday, as experts say a fix for the long-running tax provision so far has shown little effect.
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July 29, 2025
IRS To Permit Corp. AMT Top-Down Election For Partnerships
The IRS said Tuesday that revised proposed rules for the corporate alternative minimum tax will accommodate different approaches to calculating a partnership's investment income, including the top-down approach permitting a corporate partner to use figures that the partner reported in its own financial statement.
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July 29, 2025
Economists Decry Federal Budget's Looser Interest Deduction
It's regrettable that Congress loosened rules allowing companies to deduct interest costs from tax liabilities in its latest budget, which as a whole is poised to worsen the country's fiscal trajectory while prompting higher interest rates, a panel of economists said Tuesday.
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July 29, 2025
Trump To Make Call On Further Delay Of Higher China Tariffs
President Donald Trump will decide whether to extend a tariff delay another 90 days for Chinese imports after U.S. Treasury Secretary Scott Bessent and U.S. Trade Representative Jamieson Greer met with Chinese officials to discuss trade matters, the officials told reporters Tuesday in Stockholm.
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July 29, 2025
Ensure Energy Tax Credit Limit On Foreign Cos., Letter Says
The U.S. Department of the Treasury should publish guidance aimed at preventing foreign corporations from circumventing the new budget law's limits on energy tax credits by starting construction before the restrictions kick in, a solar technology and manufacturing company said in a letter Tuesday.
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July 29, 2025
Top Int'l Trade Policy To Watch In The 2nd Half Of 2025
Pervasive uncertainty surrounds international trade policy as the U.S. takes mercurial swings at the world with tariffs, including a quelled-for-now quasi embargo of China, and while lasting economic fallout hasn't materialized at home, partners abroad are aiming to replace reliance on the American market. Here, Law360 looks ahead at international trade policy during the latter half of one of the most consequential years in the field's history.
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July 29, 2025
Trump Says Britain's Tax On North Sea Oil 'Makes No Sense'
President Donald Trump criticized Tuesday the British government's 78% taxes on North Sea oil as a policy that "makes no sense," a day after speaking with Prime Minister Keir Starmer about trade and other issues.
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July 29, 2025
Ex-IRS Acting Commissioner Joins KPMG's DC Office
A former senior Internal Revenue Service employee who served as the agency's acting commissioner this year has joined KPMG LLP's Washington national tax practice as a senior managing director, the firm announced.
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July 29, 2025
Switzerland Signs Tax Treaty Update With Belgium
Switzerland reached an agreement with Belgium to add an anti-abuse clause focused on the primary purpose of transactions to the countries' tax treaty while similar changes to the Serbian-Swiss treaty have come into force, the Swiss finance ministry said Tuesday.
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July 28, 2025
New IRS Chief Rejects 'Wizard Of Oz'-Style Leadership
New Internal Revenue Commissioner Billy Long vowed Monday to engage more directly with agency employees to improve taxpayer service, emphasizing that he does not want to be a "Wizard of Oz"-style leader hiding behind a curtain.
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July 28, 2025
EU, US Agree To 15% Tariff Rate For Most Sectors
The European Union and the U.S. government have reached a deal for a 15% U.S. tariff rate on EU goods from most industry sectors, including cars, semiconductor chips and pharmaceuticals, avoiding the 30% rate that was due to take effect next month.
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July 28, 2025
US, Japanese Businessman Settle $11.6M FBAR Dispute
A Japanese businessman and the federal government have settled their $11.6 million tax filing dispute after the man claimed a language barrier was to blame and the U.S. tried to push past a jury's verdict, according to a Hawaii federal court filing.
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July 28, 2025
Britons Fear Impact Of Inheritance Tax Change On Pensions
Four out of 10 people in Britain are concerned about the government's decision to bring pensions within the scope of inheritance tax, according to a survey by a consultancy on Monday.
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July 25, 2025
Trump Trade Deals Do Little To Ease Importers' Concerns
President Donald Trump's recently announced framework trade deals offer new insight into tariff rates for several countries come Aug. 1, but experts say unanswered questions about those agreements and others still at large continue to stifle longer-term planning, leaving importers in uncertain territory.
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July 25, 2025
Ex-Credit Suisse Client Gets 2½ Years For Hiding Assets
A Florida federal judge on Friday sentenced a Colombian-American businesswoman and former Credit Suisse client to two and a half years in prison for conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.
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July 25, 2025
Russia Loses Bid To Nix Enforcement Of $63B Awards
A Singapore court on Friday denied Russia's bid to dodge litigation seeking the enforcement of more than $63 billion in arbitral awards issued to former investors in Yukos Oil Co. 11 years ago, rejecting the Kremlin's argument that it never agreed to arbitrate the dispute.
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July 25, 2025
Top International Tax Policy To Watch In 2nd Half Of 2025
The attempt by the U.S. to win an exemption for its companies from the 15% global minimum tax is the most consequential saga currently in international tax policy, but the tumultuous trade scene and anticipated guidance on Congress' tax code tinkering are also in the minds of tax professionals. Here, Law360 looks at what further changes are likely in the volatile global tax landscape during the second half of the year.
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July 25, 2025
Swiss Withholding Tax Counts For Minimum Tax, Gov't Says
Swiss multinational businesses will need to take into account Swiss withholding taxes on distributions to owners when calculating liabilities for the domestic component of the 15% global minimum tax, but not taxes paid on those distributions abroad, the Federal Tax Administration said in guidance.
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July 25, 2025
Rising Star: Gibson Dunn's Michael Q. Cannon
Michael Q. Cannon of Gibson Dunn & Crutcher LLP has been the lead attorney on several high-profile cases, including playing a key role in advising on the tax aspects of the world's largest merger and acquisition deal in 2023, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 25, 2025
IRS Provides Guidance Meant To Speed Up Corporate Audits
The Internal Revenue Service released guidance Friday that aims to make audits more efficient for corporate taxpayers, including by phasing out a document request process taxpayers had criticized as time-consuming and of little value.
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July 25, 2025
6 Things To Know About Illinois' New Tax Landscape
Illinois' latest budget has altered the state's tax system for 2025 and beyond, including by offering three tax amnesty programs, making significant changes to corporate tax law and implementing a relatively new concept for the sourcing of pass-through entity sales. Here, Law360 looks at aspects that state tax practitioners say are crucial to their clients.
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July 25, 2025
France Says It Will Accept Amount B Decisions
France will accept transfer pricing decisions made under the simplified and streamlined OECD process known as Amount B, provided they're made by an eligible low-capacity country that has a bilateral tax treaty with France, the French government said.
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July 25, 2025
Legal Org. Urges DC Circ. To Reject Trump's Tariff Powers
The D.C. Circuit should affirm a ruling that sided with toy makers and blocked President Donald Trump from using an international economic law to impose emergency tariffs because the law does not give the president the authority he claims, a legal organization argued.
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July 25, 2025
Taxation With Representation: Weil, Freshfields, Linklaters
In this week's Taxation With Representation, CC Capital and One Investment Management acquire Insignia Financial Ltd., catering giant Compass Group PLC acquires Dutch food and hospitality company Vermaat Groep BV, drugmaker Sanofi acquires biotech company Vicebio, and The Ether Machine launches as a public company.
Expert Analysis
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.