International
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July 18, 2025
IRS Offers Guidance On Use Of Transfer Pricing Exception
Taxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday.
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July 18, 2025
Trump Asks Supreme Court To Decline Early Tariff Challenge
President Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts.
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July 18, 2025
Western Union Says IRS Used Flawed Rule To Hike Income
The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.
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July 18, 2025
Taxation With Representation: Wachtell, Slaughter And May
In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.
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July 18, 2025
European Tax Policy To Watch In 2nd Half Of 2025
The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months.
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July 18, 2025
EU To Make Foreign Traders Liable For VAT On Imports
Foreign companies, rather than consumers, will become liable for value-added tax on imports to the European Union beginning July 2028 under a directive adopted Friday by the bloc's council of member states, according to a news release.
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July 18, 2025
Oman, Trinidad And Tobago 'Largely Compliant,' OECD Says
Reviews of the implementation of tax transparency measures in Oman and in Trinidad and Tobago found both nations "largely compliant" with Organization for Economic Cooperation and Development standards, the OECD said Friday.
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July 17, 2025
Canada Mulling Changes To Ability To Rewrite Transactions
Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.
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July 17, 2025
US Negotiating Global Min. Tax Carveout Accord, Official Says
The U.S. hasn't yet secured an agreement with other countries to exempt its companies from the international parts of the 15% global minimum tax despite reaching an "understanding" with the Group of 7 nations, but wider negotiations have begun, a U.S. Treasury Department official said Thursday.
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July 17, 2025
EU Warns Dutch Over Tax Breaks Favoring Foreign Investment
The Netherlands may have to face the Court of Justice of the European Union if it does not amend a tax measure that provides incentives for investment in foreign companies over domestic businesses, the European Commission announced Thursday.
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July 17, 2025
EU Lawmakers Push For Tax Data Hub To Combat Evasion
Members of the European Parliament approved proposals for tax changes across the European Union, including a tax data hub to streamline compliance across the bloc and help combat tax avoidance and evasion.
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July 17, 2025
US Challenge To Belgian Minimum Tax Rules Heads To ECJ
A Belgian court said Thursday it has asked the European Union's highest court to weigh in on a U.S. industry group's challenge to the country's global minimum tax rules.
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July 17, 2025
Tax Info Swaps Have Generated €135B Since 2009, OECD Says
The international push for widespread adoption of tax transparency measures such as exchanges of information has led to €135 billion ($156 billion) in added revenue — including taxes, penalties and interest — since 2009, the Organization for Economic Cooperation and Development said Thursday.
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July 17, 2025
Australia Seeks Comments On Pillar 2 Guidance
The Australian Taxation Office is looking for public comments on a pair of draft guidelines related to the country's adoption of the Organization for Economic Cooperation and Development's Pillar Two global corporate minimum tax on large multinational entities.
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July 16, 2025
OECD Mulling Tweaks To Arm's-Length Range Guidance
The Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday.
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July 16, 2025
Tax Losses Back Retired Prof's FBAR Penalties, US Says
A retired professor's admission in U.S. Tax Court that his failure to report his foreign bank accounts caused tax losses shows that a California federal court should affirm tax penalties against him of more than $400,000, the U.S. government said.
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July 16, 2025
EU Proposes New Tax On Large Cos. In Budget For 2028-2034
The European Commission raised the idea Wednesday of a new tax on all companies that operate in the European Union with more than €100 million ($116 million) in annual revenue to augment its €2 trillion budget proposal for 2028 through 2034.
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July 16, 2025
German Chancellor Calls For EU Halt To Global Minimum Tax
German Chancellor Friedrich Merz has called for the suspension of the European Union's rollout of the global corporate minimum tax, a German newspaper reported Wednesday.
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July 16, 2025
USTR To Probe Brazil's Trade Practices For Possible Tariffs
The Office of the U.S. Trade Representative announced Tuesday evening it will launch an investigation into Brazil's trade practices to determine whether tariff actions could be necessary after a request by President Donald Trump and prior tariff threats.
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July 16, 2025
India Uses AI In Fraudulent Tax Crackdown, Recovers $122M
A sweeping enforcement operation by the Indian tax authority used artificial intelligence and third-party financial data to uncover widespread abuse of tax deductions and exemptions, so far recovering 1,045 crore rupees ($122 million), the government said.
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July 16, 2025
Freight Co. Loses Interim Bid To Lift HMRC Export Controls
A warehouse operator and drinks merchant have lost a bid for interim relief against U.K. tax authority export controls imposed over tax fraud concerns, with a London court ruling they had an "uphill task" to prove the measures were unreasonable.
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July 15, 2025
Trump Says US Has Struck Trade Deal With Indonesia
President Donald Trump announced Tuesday that the U.S. has reached a trade deal with Indonesia that includes a 19% tariff on all goods exported by the Southeast Asian country to the U.S., while American goods exported there will be free of tariffs.
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July 15, 2025
Tax Return Preparer Cops To Role In $25M Fraud Scheme
A tax return preparer pled guilty in a California federal court for his role in a fraud scheme that involved submitting fake federal income tax returns to claim $25 million in refunds.
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July 15, 2025
UK Tech Co. Can't Deduct Tax Linked To VAT Fraud
HM Revenue & Customs was correct to deny a technology supplier's £1.3 million ($1.7 million) tax refund bid, a U.K. court ruled, holding that the company should have known that the underlying transactions were tied to value-added tax fraud.
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July 15, 2025
Insurers Keen On UK Captive Regime But Fear 'Gold-Plating'
The government has proposed new rules that it hopes will transform the U.K. into a global hub for captive insurance — but experts say that with formal regulation still to come they fear that "the devil will be in the detail."
Expert Analysis
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Adapting To Private Practice: From NY Fed To BigLaw
While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.
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Top 3 Litigation Finance Deal-Killers, And How To Avoid Them
Like all transactions, litigation finance deals can sometimes collapse, but understanding the most common reasons for failure, including a lack of trust or a misunderstanding of deal terms, can help both parties avoid problems, say Rebecca Berrebi at Avenue 33 and Boris Ziser at Schulte Roth.
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A 2-Step System For Choosing A Digital Asset Reporting Path
Under the Internal Revenue Service's new digital asset reporting regulation, each type of asset may have three potential reporting destinations, so a detailed testing framework can help to determine the appropriate path, says Keval Sonecha at Sonecha & Amlani.
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.