International
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August 11, 2025
Gov'ts Mull Gross Basis Tax For Services In UN Convention
A number of developing countries argued Monday that gross basis taxation is the easiest-to-administer option for overcoming inequitable transfer pricing rules within a protocol on taxing cross-border services in the United Nations framework convention on international tax cooperation.
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August 11, 2025
Goodyear Facing Tax Adjustments Over Intercompany IP Sale
Goodyear Tire & Rubber Co. is planning to challenge proposed IRS adjustments that could undermine the company's ability to offset certain taxes related to an intercompany intellectual property sale, according to a U.S. Securities and Exchange Commission filing.
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August 11, 2025
6th Circ. Orders Eaton To Give Employee Records To IRS
The Sixth Circuit affirmed an Ohio federal judge's order requiring Eaton Corp. to share performance evaluations for Ireland-based workers with the IRS, holding that the agency's interest in investigating potential tax liabilities outweighs Ireland's privacy interest, which the court said was "weak" at best.
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August 11, 2025
Kostelanetz Hires Most Recent DOJ Tax Division Leader
The immediate past head of the U.S. Department of Justice's Tax Division will join Kostelanetz LLP as a partner in Washington, D.C., amid a sweeping restructuring that would split the division's criminal and civil tax functions and place them in the department's main branches.
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August 11, 2025
2nd Circ. Affirms Denial Of Partnership's $22.7M Tax Loss
The U.S. Tax Court correctly found the IRS properly denied a Connecticut partnership's $22.7 million loss deduction because the underlying transactions, which involved a Brazilian company, were tantamount to a disguised property sale, the Second Circuit ruled Monday.
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August 08, 2025
DC Circ. Hands Banker's Estate Win In IRS Whistleblower Bid
A split D.C. Circuit sided with the estate of a former banker at Rabobank in ruling Friday that the Internal Revenue Service used the wrong legal standard to deny him an award for contributing to investigations into two companies' tax avoidance scheme.
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August 08, 2025
Trump Ousts IRS Commissioner Weeks After Confirmation
Billy Long has been removed from his role as Internal Revenue Service commissioner after spending just shy of two months as head of the agency, the White House said Friday.
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August 08, 2025
Italy Cuts Corporate Tax Rate For Capital Goods Investment
Italy began offering a lower corporate tax rate Friday to companies that invest in capital goods, including those that reduce energy consumption, or in hiring new employees, provided they don't lay off workers in either case, according to the Economy and Finance Ministry.
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August 08, 2025
South Korea Probes 49 Foreign Luxury Apartment Buyers
South Korea's National Tax Service said it has launched a tax evasion probe into 49 owners of high-priced apartments who are from foreign countries such as the U.S. and China.
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August 08, 2025
Swiss Metals Group Fears US Tariffs' Impact On Gold
The U.S.-imposed 39% tariffs on Switzerland may "negatively impact" gold trading, a Swiss metals association warned Friday.
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August 08, 2025
11th Circ. Vacates Russian Gas Ex-CFO's Tax Crime Sentence
The Eleventh Circuit vacated a Russian former gas executive's seven-year prison term and order to pay $4 million in restitution to the IRS, saying federal prosecutors were wrongly given extra time to bring charges against him for failing to file income tax returns.
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August 08, 2025
Australia Lifts PwC Bid Ban, Citing Changes After Tax Leak
PwC Australia is no longer banned from bidding on government contracts now that the firm has shown "ethical soundness" after a scandal involving the leak of government tax documents, the Australian Department of Finance said Friday.
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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.
Expert Analysis
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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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.