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May 11, 2026
APA Results Should Make Sense Annually, IRS Official Says
Taxpayers seeking advance pricing agreements with the Internal Revenue Service will now be expected to have the results of an agreed-upon transfer pricing method comply with the method on an annual basis rather than only over the multiple years covered by the APA, an IRS official said Monday.
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May 11, 2026
Amgen Late To Raise Double-Taxation Claim, Tax Court Told
Biotechnology giant Amgen is making a "futile" attempt to raise a purported double-taxation issue for tax years 2016 through 2018 in a pair of transfer pricing cases before the U.S. Tax Court, the federal government said, arguing the disputed years fall outside the court's jurisdiction.
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May 11, 2026
Australia Preparing Decisions On Capital Gains Tax Issues
Australia is preparing determinations and guidance on five issues related to capital gains taxation, including when anti-avoidance laws may be applied to multiple deferrals of liabilities and how the tax applies when a cryptocurrency is pegged to another cryptocurrency, the Australian Taxation Office said Monday.
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May 11, 2026
1 In 3 Large UK Companies Faced HMRC VAT Probe
Britain's tax authority investigated one in three large companies on value-added tax matters in financial year 2024-25 as part of efforts to crack down on noncompliance, according to official data.
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May 11, 2026
McKesson Says Loper Bright Sinks IRS Cost-Sharing Rules
Pharmaceutical giant McKesson asked a Texas federal court to strike down cost-sharing transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. Supreme Court's Loper Bright ruling forecloses previous deference to rule writers.
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May 09, 2026
IRS Scrutiny Of Immigrant Employment Tax Fraud To Continue
Scrutinizing businesses with potential employment tax fraud issues related to undocumented immigrants will remain among the Internal Revenue Service Criminal Investigation division's top priorities, a senior division executive said Saturday.
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May 09, 2026
Spinoff Letter Rulings Valuable For IRS Too, Agency Atty Says
The Internal Revenue Service has resumed issuing letter rulings on significant issues in tax-free spinoffs, and an IRS attorney on Saturday encouraged companies to use the program, as it provides the agency with valuable information on the transactions.
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May 09, 2026
Admin Cost Of Tax Presence Shouldn't Top Profit, Pros Say
The administrative costs for a company or individual triggering a taxable presence, or permanent establishment, in a jurisdiction shouldn't exceed the profit allocable to the entity, transfer pricing specialists said Friday.
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May 08, 2026
AI's Use In Transfer Pricing Still Evolving, Tax Pros Say
The use of artificial intelligence in transfer pricing is expected to ease compliance and reduce costs for clients, but multiple questions remain about the technology's potential and how it should be applied, a panel of tax experts said Friday.
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May 08, 2026
Disbarred Atty Can't Escape Tax Evasion Case, 2nd Circ. Says
A disbarred English attorney who assisted the heirs of an American businessman in evading taxation on their inheritance cannot use an "extraordinary" post-conviction remedy to overturn part of the verdict and a $4 million restitution bill, the Second Circuit ruled Friday.
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May 08, 2026
Nike Customers Join Tariff Refund Class Action Trend
A group of Nike customers on Friday joined the growing number of proposed class actions looking to secure legal rights to refunds of costs tied to President Donald Trump's now-invalidated global tariff regime, saying they were the ones who actually bore the costs.
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May 08, 2026
Why Trump's 2nd Global Tariff May Fare Better On Appeal
President Donald Trump's administration on Friday appealed the U.S. Court of International Trade's ruling deeming his temporary global tariff unlawful to the Federal Circuit, where judges may view the executive action with more deference than the measures it immediately replaced.
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May 08, 2026
Clarity Sought On Energy Tax Credits And Foreign Debt
The IRS should issue more guidance on what kind of debt arrangements can limit a development project's access to clean energy tax credits under new prohibited foreign entity requirements as uncertainty over financial liability and ownership becomes a major market concern, practitioners said Friday.
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May 08, 2026
US, Romania Have Wrapped Up Tax Treaty Talks, Official Says
The U.S. and Romania recently completed negotiations on their double-tax treaty and are conducting reviews of the changes, an official with the U.S. Department of the Treasury said Friday.
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May 08, 2026
Former Exec Didn't Prove Resignation, Canada Tax Court Says
A businessman didn't exercise due diligence and failed to prove he stepped down from a company position, leaving him liable for unremitted goods and services taxes, a Toronto court ruled.
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May 08, 2026
Taxation With Representation: Corrs, Kirkland, Linklaters
In this week's Taxation With Representation, gold companies Regis Resources and Vault Minerals combine, Long Lake Management acquires American Express Global Business Travel and Vodafone buys out CK Hutchison Holdings to become the sole owner of their telecommunications joint venture.
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May 08, 2026
UK Dentist Wins Appeal To Overturn £225K In Tax Penalties
A London tribunal canceled tax penalties totaling nearly £225,000 ($306,000) that Britain's tax authority imposed on a dentist who unwittingly joined a fraudulent tax scheme on the advice of his accountant.
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May 08, 2026
Liberty Global Easy Case For 10th Circ., IRS Atty Says
The Internal Revenue Service's recent win against telecommunications giant Liberty Global, whose complex transactions were held to be a tax shelter lacking economic substance, was an "easy affirmance" for the Tenth Circuit and an easy decision for the district court, an agency official said Friday.
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May 07, 2026
Trump's Temporary Global Tariffs Illegal, Trade Court Rules
President Donald Trump's temporary global 10% tariffs are unlawful because the narrow set of economic conditions required for the measure to be imposed were not met, the U.S. Court of International Trade said Thursday in a divided opinion.
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May 07, 2026
Wyden Probes Wall Street Firms For Tariff Refund Stakes' Info
The top Democratic lawmakers on the Senate Finance Committee sent letters to major Wall Street firms Thursday about their activity in buying the rights to importers' tariff refund interests at a discount following the U.S. Supreme Court's decision in February striking down President Donald Trump's emergency tariff regime.
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May 07, 2026
Carbon Tax Revenues Fall Far Short Of Potential, Report Says
Carbon taxes worldwide raised less than a third of the revenue they could have recently, weighed down by exemptions, reduced rates, compliance gaps and other carbon pricing systems carving out the tax base, the Tax Foundation said Thursday in a report.
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May 07, 2026
Stinson Real Estate Finance Atty Joins Reed Smith In DC
Reed Smith LLP has hired a Stinson LLP lawyer who focuses her practice on real estate finance matters, renewable energy tax credit and new market tax credit issues, the firm has announced.
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May 07, 2026
Italian Man Arrested Amid Probe Into Large-Scale VAT Fraud
Italian authorities have arrested a businessman suspected of laundering the proceeds of a multimillion-euro value-added tax fraud, the European Public Prosecutor's Office said.
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May 07, 2026
Iran War Risks £8B Annual Tax Hit To UK, Report Warns
The Iran war could cost the U.K. government up to £8 billion ($10.9 billion) a year through lost tax revenue and higher debt interest payments, a progressive think tank warned Thursday.
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May 07, 2026
Iran War Sees Germany Downgrade Tax Revenue Expectations
Germany downgraded its tax revenue forecasts Thursday at all levels of government for each year through 2030 due to the Iran war.
Expert Analysis
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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.
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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.