International

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • September 22, 2025

    VC Partner Fights IRS Summonses Tied To Korean Tax Probe

    A partner at a U.S. venture capital firm urged a California federal court to quash IRS summonses seeking information on his bank accounts in connection with his tax liabilities in South Korea, saying the agency failed to meet requirements for enforcing the summonses.

Expert Analysis

  • Reading The Tea Leaves On Mexico, Canada And China Tariffs

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    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.

  • How Design Thinking Can Help Lawyers Find Purpose In Work

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    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.

  • The Pros And Cons Of A 2nd Trump Term For UK Tech Sector

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    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.

  • Corp. Transparency Act's Future Under Treasury's Bessent

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    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.

  • A Look At A Possible Corporate Transparency Act Exemption

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    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.

  • Inconsistent Injury-In-Fact Rules Hinder Federal Practice

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    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.

  • In-House Counsel Pointers For Preserving Atty-Client Privilege

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    Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.

  • Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example

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    Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.

  • Accountant-Owned Law Firms Could Blur Ethical Lines

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    KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.

  • AI Will Soon Transform The E-Discovery Industrial Complex

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    Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.

  • Unpacking The Legal Foundation Of Trump's New Trade War

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    President Donald Trump's recent executive orders and proclamations regarding emergencies at the U.S. border are based on statutory powers enabling a president to address extraordinary external threats — and could be used to fend off legal challenges to the tariffs levied on Mexican and Canadian goods, says Chris Zona at Mandelbaum Barrett.

  • When Innovation Overwhelms The Rule Of Law

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    In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.

  • Imagine The Possibilities Of Openly Autistic Lawyering

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    Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.

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