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April 21, 2026
IRS Says Meta Pricing Adjustments Not Barred By Prior Ruling
The U.S. Tax Court's opinion on the pricing of Meta predecessor Facebook's transferred intangible assets doesn't prevent the IRS from making periodic adjustments based on transactions occurring over the life of the company's cost-sharing arrangement with an Irish subsidiary, the agency argued.
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April 21, 2026
UK Exit Tax Ruling Is Judicial Overreach, Court Told
A tribunal overstepped its authority by ruling in favor of Britain's tax authority to impose an exit tax on U.K. trusts leaving the country in breach of European Union law long before Brexit was enacted, a trust argued before a London appeals court Tuesday.
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April 21, 2026
IRS Lists Over 1,400 Individuals Who Lost US Citizenship
The Internal Revenue Service on Tuesday issued a list of more than 1,400 individuals who lost U.S. citizenship during the first quarter of the year, a slight uptick from a year ago.
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April 21, 2026
GE Says IRS Is Probing Its Tax Math Under 2017 Overhaul
The Internal Revenue Service is auditing General Electric's income tax returns over computations the company made under the 2017 federal tax overhaul, according to a Tuesday filing with the U.S. Securities and Exchange Commission.
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April 21, 2026
Payroll VAT Fraudsters Jailed For 22 Years
Four directors of a payroll company were sentenced to more than 22 years in prison for a two-year £8.8 million ($11.9 million) value-added tax fraud scheme, HM Revenue and Customs said Tuesday.
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April 20, 2026
Buy.com Founder Says IRS Missed Deadline For $16M Bill
The founder of now-defunct Buy.com told the Tenth Circuit that the IRS cannot use "a patchwork of documents" to show it didn't miss the window to hit him with a nearly $16 million tax bill, pushing for reversal of a U.S. Tax Court decision.
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April 20, 2026
UK Co. Should Have Known About VAT Fraud, Tribunal Says
A computer company should have known it was dealing with value-added tax fraudsters whose business was too good to be true, so HMRC's denial of a nearly £430,000 ($582,000) tax deduction is valid, the First-tier Tribunal said in a decision.
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April 20, 2026
Irish Co. Defeats £18M Tax Appeal Over Lehman Bros. Debt
HM Revenue & Customs can't retain over £18 million ($24.3 million) in a withholding tax claimed by an Irish company on debt interest from collapsed bank Lehman Brothers, a London court ruled Monday.
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April 20, 2026
Dutch Gov't Provides Tax Breaks To Ease Oil Crisis
The Netherlands is implementing tax breaks to help citizens and businesses weather the oil crisis caused by the closing of the Strait of Hormuz, a consequence of the U.S. and Israel's war on Iran, the Dutch Cabinet said Monday in a letter to Parliament.
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April 20, 2026
Reform UK Deputy Says His Co. May Have Made Tax Errors
Reform UK deputy Richard Tice said "some errors" are inevitable when running multiple businesses following a report that his investment company failed to pay almost £100,000 ($135,000) in corporate tax, adding that he would pay up if it is found he owes more taxes.
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April 17, 2026
3 Key Questions On Trump's Pharma Tariffs
President Donald Trump recently announced 100% tariffs on certain imported pharmaceutical products, with opportunities for drug companies to lower their tariff rates to zero, but questions remain about the requirements for preferential treatment and abilities to administer the regime. Here, Law360 examines three open questions surrounding pharmaceutical tariffs' implementation.
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April 17, 2026
Tax Arbitrage Guidance Due This Year, OECD Official Says
The Organization for Economic Cooperation and Development hopes to publish guidance this year on tax arbitrage that could be relevant to the application of what's known as the Pillar Two side-by-side package, created to recognize the U.S. minimum tax system, an OECD official said Friday.
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April 17, 2026
Brexit Backer Owes Inheritance Tax On Donations, Court Says
A former hedge fund manager who donated about £750,000 ($1 million) to political groups that mostly advocated for Brexit isn't exempt from about £100,000 of inheritance tax on his donations, the First-tier Tribunal said in a judgment.
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April 17, 2026
Taxation With Representation: Skadden, Stikeman Elliott
In this week's Taxation With Representation, Amazon.com Inc. buys satellite communications company Globalstar Inc., waste management company GFL Environmental Inc. acquires Secure Waste Infrastructure Corp., and Standard Life PLC buys the British subsidiary of Dutch insurer Aegon.
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April 17, 2026
Furniture Cos.' $19M Captive Insurance Scam Suit Resumed
A Maryland federal court has resumed a lawsuit accusing a D.C. corporate tax attorney and his former law firm of a $19 million captive insurance scam following notification that the bankruptcy proceedings of the attorney and the firm have concluded.
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April 17, 2026
Taxing Digital Economy Gaining More Traction, OECD says
An official from the Organization for Economic Cooperation and Development said Friday that the Paris-based group is engaging in constructive dialogue on the taxation of the digital economy as interest in the subject grows.
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April 16, 2026
Senate Bill Seeks To End Carried Interest Tax Break
Fund managers would face annual taxation of carried interest based on imputed compensation, instead of primarily enjoying long-term capital gains rates, under a bill introduced Thursday by Senate Finance Committee ranking member Ron Wyden, the latest in a decades-long drive to end the tax break.
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April 16, 2026
UK Travel Co. Can Challenge VAT Credit Adjustment
A travel agency can proceed with challenging HM Revenue & Customs' trimming of its value-added tax credit by about £187,000 ($253,000) after a court spiked the U.K. tax authority's bid for an early end to the case.
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April 16, 2026
UK Firms Wary Of Loan-Out Contracts, Paramount VP Says
Companies across various industries are becoming more hesitant to employ people via loan-out firms because of concerns about their own tax liabilities, a Paramount Global vice president said Thursday.
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April 16, 2026
Texas Judge Vacates IRS' Steep Microcaptive Reporting Rule
A Texas federal judge vacated a tax code regulation designating microcaptive insurance transactions as listed transactions subject to deep scrutiny and hefty penalties, saying the Internal Revenue Service didn't prove that they are mostly for tax avoidance and not really for insurance.
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April 16, 2026
Defunct Canada Law Firm Can't Get Bad Debt Tax Deduction
A shuttered Canadian law firm can't get a tax break on unpaid client bills, the Tax Court of Canada ruled, holding that the firm didn't make a sufficient effort to chase down payments before claiming a bad debt deduction.
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April 16, 2026
OECD To Address Double-Tax Policy Quirk, Official Says
The Organization for Economic Cooperation and Development is working to iron out a policy quirk that can result in double taxation when it is unclear whether restrictions on interest deductions fall under domestic tax rules or international treaty frameworks, an OECD official said Thursday.
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April 16, 2026
Canadian Bank Defeats Country-By-Country Tax Proposal
Shareholders of the Canadian Imperial Bank of Commerce voted against a proposal to require the bank to disclose public country-by-country reports of tax information Thursday, with only about 10% of shareholders voting in favor.
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April 15, 2026
Centrica Loses £5.3M Tax Dispute Over North Sea Gas Field
Centrica's activities in a North Sea natural gas field amount to oil extraction, and therefore the company is liable for corporate tax bills totaling £5.3 million ($7.2 million) under the rules governing energy taxation, according to a London tribunal.
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April 15, 2026
Cross-Border Services Taxes Are 'Quasi-Tariffs,' Report Says
The U.S. arguably has a stronger interest in challenging digital services taxes and other "quasi-tariffs" than in pursuing tariffs on physical goods, according a report Wednesday from the Tax Foundation, which contended that these overseas taxes disproportionately harm large services exporters.
Expert Analysis
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How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.
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Preserving Refunds As Tariffs Await Supreme Court Weigh-In
In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.
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Writing Musicals Makes Me A Better Lawyer
My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.
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Adapting To Private Practice: From Va. AUSA To Mid-Law
Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.
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7 Document Review Concepts New Attorneys Need To Know
For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.
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Agentic AI Puts A New Twist On Attorney Ethics Obligations
As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.
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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.