International
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October 31, 2025
OECD Reports Rise In Failed Advance Pricing Agreements
The number of advance pricing agreements that were rejected or closed without an accord rose 19% last year compared with the previous year, and slightly fewer agreements were granted overall, the Organization for Economic Cooperation and Developmen said Friday.
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October 31, 2025
UK Co. Can't Shake £8.4M Tax On Goods Imported For Repair
A U.K. subsidiary of a U.S. industrial equipment company isn't entitled to recover roughly £8.4 million ($11 million) in value-added tax on goods it brought into the U.K. for repair and servicing, a London tribunal ruled.
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October 31, 2025
OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases
Tax authorities began more than 2,500 mutual agreement procedure cases last year involving transfer pricing, a record number representing a 29% increase from the previous year, the Organization for Economic Cooperation and Development said Friday.
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October 31, 2025
Taxation With Representation: Skadden, Davis Polk
In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.
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October 31, 2025
Australia Issues Guidance On Public Country-By-Country Law
Australia issued guidance Friday on how to comply with its public country-by-country reporting law, including filing instructions, formatting and the information required to be disclosed.
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October 31, 2025
5 Indicted In Germany In €188M VAT Fraud Scheme
Five German residents have been indicted on charges related to their participation in a €188 million ($217 million) value-added tax fraud scheme, European Union authorities said Friday.
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October 30, 2025
Trade Deals At Risk In Trump Tariff Case, Feds Tell Justices
The federal government told the U.S. Supreme Court on Thursday that President Donald Trump's global tariffs have led to significant trade deals addressing the underlying national emergencies he declared, and a ruling determining them unlawful would prove catastrophic.
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October 30, 2025
China Delays Expanded Mineral Export Controls, Trump Says
China has agreed to delay for a year an expansion to export controls for key minerals and is set to start purchasing more U.S. agricultural products including soybeans, while U.S. tariffs on Chinese goods will decrease 10%, President Donald Trump said early Thursday morning.
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October 30, 2025
Senate Votes To Ax Global Tariffs, But House Path Blocked
The Senate passed legislation Thursday to end the declared national emergency propping up President Donald Trump's global tariff regime shortly after passing similar bills regarding tariffs on Canada and Brazil, though the House previously moved its deadline for action on the matter to next year.
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October 30, 2025
IRS Discloses Record In ICE Data Sharing Case
The IRS, following a judge's order, has released its administrative record in a lawsuit over its agreement to share taxpayer information with federal immigration authorities, including emails in which officials discuss U.S. Immigration and Customs Enforcement's request for information on nearly 1.3 million taxpayers.
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October 30, 2025
French Legislators Vote To Double Digital Services Tax To 6%
Lawmakers in the lower house of France's Parliament voted to double the country's digital services tax rate from 3% to 6%, stopping short of an earlier proposal to increase the measure to 15% to mirror U.S. tariffs.
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October 30, 2025
Dutch Centrist Party Gains Seats With Tax Change Agenda
The centrist party Democrats 66 looks set to come out of the Dutch general election as the party best placed to lead the next government with an agenda to cut taxes for working people and raise rates on wealth and pollution, according to balloting counted Thursday.
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October 30, 2025
EU's Top Court Axes Dutch Co.'s Challenge Against Pillar 2
The European Union's top court declined Thursday to revive a Dutch company's case against an EU directive that implements an international minimum tax agreement known as Pillar Two, holding that the business lacked standing to challenge the law.
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October 29, 2025
Senate Backs Axing Brazil Tariffs, But House Vote Blocked
The Senate voted to end a declared national emergency underpinning U.S. tariffs placed on Brazil for the prosecution of its former president over an attempted coup, but the House has delayed a statutory requirement to expedite accompanying legislation.
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October 29, 2025
Tribunal Walks Back HMRC's £1M Share Sale Decision
HM Revenue & Customs incorrectly increased a man's income tax liability by over £1 million ($1.3 million) on the sale of shares in a company as part of his retirement plan, a London tribunal ruled.
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October 29, 2025
IRS Wrongly Nixed Insurance Transactions, Tax Court Told
A Tennessee company that claims to provide in-house insurance to businesses supporting the U.S. Department of Defense and NATO has challenged more than $500,000 in tax liabilities and the IRS' denial of its status as an insurer, according to a U.S. Tax Court petition.
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October 29, 2025
Publix Heiress Asks To Quash IRS Summons For Bank Info
An heiress to the Publix grocery store chain asked a Florida federal court to quash an IRS summons seeking her bank information on behalf of Italian tax officials, arguing that the agency's request flouts the Italy-U.S. tax treaty.
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October 29, 2025
Top UK Court Rules NHS Parking Services Subject To VAT
Britain's top court ruled Wednesday that provision of car parking services by a National Health Service trust should not be exempt from value-added tax, a decision that will affect dozens of stayed appeals by NHS entities worth up to £100 million ($132 million).
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October 28, 2025
Baltimore Atty Found Personally Liable For Entity's Taxes
A Baltimore attorney who manages a client's holding company is personally responsible for paying the entity's unpaid taxes, a Maryland federal judge said, finding that he approved and oversaw loan transactions that prompted the IRS to seek $2 million from the entity.
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October 28, 2025
Shutdown Raises Concerns About IRS Reg Timing, 2026 Filing
The federal government shutdown is likely to delay critical IRS guidance for retroactive tax provisions in this summer's budget bill and impair customer service at the agency as it drags on, causing headaches for taxpayers, tax observers say.
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October 28, 2025
US, Japan Sign Agreement On Key Minerals
The U.S. and Japan agreed Tuesday to coordinate on securing and refining important minerals, while outlining a series of Japanese investments in U.S. industries, according to an announcement published by the White House.
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October 28, 2025
Norway Sees 30% Spike In Crypto Reporting To Tax Authority
Norway saw a 30% spike in taxpayers who reported owning cryptocurrency last year, the country's tax authority said Tuesday, attributing the increase to its compliance efforts.
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October 28, 2025
UN Committee Seeks Feedback On Tax Treaty, Dispute Ideas
Leaders of the intergovernmental negotiating committee on the United Nations framework convention on international tax cooperation are seeking comments on a template for the treaty and ideas for a protocol on dispute resolution.
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October 27, 2025
Cambodia Agrees To Cut Tariffs, Barriers In US Trade Deal
Cambodia agreed to cut tariffs, refrain from imposing a digital services tax, remove nontariff trade barriers and accept U.S. regulatory standards in a trade agreement with the U.S. in exchange for tariff exemptions.
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October 27, 2025
US Unveils Trade Frameworks For Vietnam, Thailand Deals
The U.S. issued new details on a framework trade deal it reached months ago with Vietnam and announced a new framework deal with Thailand, according to announcements made by the White House on Sunday.
Expert Analysis
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Opportunity Zone's Future Corp. Tax Benefits Still Uncertain
Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.
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How GILTI Reform Affects M&A Golden Parachute Planning
Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.
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Demystifying The Civil Procedure Rules Amendment Process
Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.
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Parenting Skills That Can Help Lawyers Thrive Professionally
As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.
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Trump Tax Law's Most Impactful Energy Changes
The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.
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Adapting To Private Practice: From Texas AUSA To BigLaw
As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.
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Advice For 1st-Gen Lawyers Entering The Legal Profession
Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.
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Trump Tax Law's Most Impactful Corp. And Individual Changes
The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.
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From Clerkship To Law Firm: 5 Transition Tips For Associates
Excerpt from Practical Guidance
Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.