International
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May 02, 2025
Money Laundering, Tax Charges Nixed Vs. Crypto Operator
An Indiana federal judge dismissed the U.S. government's cases against a man accused of operating an unlicensed money transmitting business, laundering proceeds through cryptocurrency transactions and failing to file tax returns after finding his business was not subject to registration requirements, as the government had maintained.
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May 02, 2025
Glencore Exec Can't Duck Tax On £150M In Offshore Shares
Glencore's former head of oil failed to overturn a finding he was liable for income tax on nearly £150 million ($200 million) in share distributions from the Jersey-incorporated company, when an appeals court concluded Friday it was subject to U.K. taxation.
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May 02, 2025
IRS Updates Rates For Foreign Insurance Company Equations
The Internal Revenue Service on Friday published updated domestic asset/liability and yields percentages for 2024 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.
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May 02, 2025
Taxation With Representation: Goodwin, Haynes Boone
In this week's Taxation With Representation, Merck buys SpringWorks Therapeutics, Novartis AG acquires Regulus Therapeutics Inc., Sabre Corp. sells its Hospitality Solutions business to private equity shop TPG, and TWG Global and Mubadala Capital team up to bolster their investments.
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May 02, 2025
Community Groups Accept Pause In CTA Litigation
A group of community associations has told the Fourth Circuit they aren't opposed to a government motion to pause litigation over the Corporate Transparency Act, even as they maintained the information disclosure law aimed at small businesses still carries constitutional flaws.
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May 01, 2025
Irish Tax Appeals Board Closed €355M In Cases In 2024
Ireland's Tax Appeals Commission closed more than 1,711 appeals cases in 2024, a 12% increase over the year prior and valued at €355 million ($401 million) in taxes, the commission said in a report.
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May 01, 2025
Multinationals Grapple With Tariff-Induced Pricing Issues
President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.
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May 01, 2025
Trump Picks Tax Controversy Pro For IRS Chief Counsel Spot
President Donald Trump has tapped a former Internal Revenue Service chief counsel to return to the role, and if he is confirmed, it will represent the second time in his career that the veteran tax controversy professional will be the agency's top attorney.
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May 01, 2025
Chilean Digital Platforms Must Show Users' Tax Compliance
Digital platforms operating in Chile will need to show that those either contracting their services or using them to offer their owns goods and services are tax-compliant starting in 2026, Chile's tax administration said.
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May 01, 2025
Canada Looks To Guide Exporters Navigating US Tariffs
The Canadian government is offering new resources for exporters dealing with what it called unjustified U.S. tariffs, providing information on rules of origin and customs procedures under the U.S.-Canada-Mexico Agreement.
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May 01, 2025
Estate Pushes Back On IRS In DC Circ. Lost Records Case
The estate of a man whose offshore businesses were raided by the IRS, giving rise to a nearly $18 million tax judgment, criticized the agency's effort to rebuff the estate's claims to the D.C. Circuit that the IRS fraudulently claimed that boxes of evidence in ensuing litigation were lost.
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May 01, 2025
Ore. Tax Court Retains Nix Of Microsoft Foreign Income Relief
The Oregon Tax Court is adhering to its finding on the treatment of Microsoft's repatriated foreign income when calculating its state income, making only minor changes to an earlier order and rejecting the company's arguments for further relief.
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May 01, 2025
ECB Says Consumers Ready To Avoid US Goods Over Tariffs
European consumers are prepared to avoid American goods for the long term, following the impact of tariffs imposed by the U.S. administration, according to a survey by the European Central Bank.
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May 01, 2025
BNY Can't Escape A&O Shearman's £93M Negligence Claim
Bank of New York Mellon lost its fight Thursday to escape a claim from Allen Overy Shearman Sterling alleging that the lender caused Nationwide Building Society to face a £93 million ($109 million) tax bill by bungling the issuance of notes.
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April 30, 2025
Senate Rejects Bill To End Trump's Nat'l Emergency On Tariffs
The U.S. Senate narrowly rejected a bipartisan bill Wednesday that sought to end the national emergency declared by President Donald Trump to underpin his global tariff regime, with two senators absent for the vote, and with U.S. House consideration delayed until October.
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April 30, 2025
Workers' Effective Tax Rates In OECD Up Again, But So Is Pay
While the effective tax rates on labor across the Organization for Economic Cooperation and Development's 38 member countries on average ticked up for a third year in a row in 2024, average wages were up in all but four countries after dropping over the prior two years, the OECD said Wednesday.
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April 30, 2025
US Economy Shrank 0.3% In First Quarter As Imports Surged
U.S. gross domestic product fell at an annual rate of 0.3% in the first quarter of 2025 as importers stockpiled goods in advance of President Donald Trump's global tariff regime, the U.S. Department of Commerce announced Tuesday.
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April 30, 2025
EU Busts $10M VAT Fraud Ring Involving Chinese Imports
The European Anti-Fraud Office and Polish authorities uncovered a value-added tax fraud ring that exploited European Union rules to dodge over 38.2 million Polish zloty ($10.1 million) in value-added taxes on goods imported from China, they said Wednesday.
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April 30, 2025
Morgan Lewis Expands Tax Practice With Milbank Hire
Morgan Lewis & Bockius LLP added a former Milbank special counsel as a tax partner based in the firm's London office.
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April 30, 2025
Dentist Fights HMRC Over Alleged Tax Avoidance
A dentist's firm urged an appeals court on Wednesday to find that it had not engaged in tax avoidance by making loan payments to its owner through a trust, saying the payments had no connection to its owner's employment and therefore were not taxable as income.
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April 30, 2025
Switzerland Begins Consultation On Pillar 2 Return Rules
The Swiss government said Wednesday that it has begun the consultation process to create compliance rules for a global information return that companies must submit as part of an international minimum corporate tax agreement known as Pillar Two.
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April 30, 2025
Sheppard Mullin Brings On Kirkland Tax Ace In Houston
Sheppard Mullin Richter & Hampton LLP announced Wednesday that it expanded its tax, employee benefits and trusts and estates practice with a new partner most recently with Kirkland & Ellis LLP.
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April 30, 2025
Dem Reps. Urge Court To Block IRS-ICE Info-Sharing Pact
House Democrats and two organizations that help immigrants prepare tax returns urged a D.C. federal court to block the Internal Revenue Service from sharing with immigration enforcement agencies the names and addresses of people suspected of being in the country illegally.
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April 30, 2025
Fried Frank Taps Sidley's UK Tax Head
The former head of Sidley Austin LLP's U.K. tax practice has joined Fried Frank Harris Shriver & Jacobson LLP's London office, where he will advise on U.K. and international tax structuring, the firm announced.
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April 30, 2025
Ex-Treasury Official Joins Baker McKenzie's Tax Practice
Baker McKenzie has hired a former deputy assistant secretary at the Treasury Department to work on international tax matters as a partner in the firm's office in Washington, D.C.
Expert Analysis
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Firms Must Rethink How They Train New Lawyers In AI Age
As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.
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Think Like A Lawyer: Always Be Closing
When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.
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Lean Into The 'Great Restoration' To Retain Legal Talent
As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.
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Fishing Makes Me A Better Lawyer
Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge at Robinson Bradshaw.
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A Healthier Legal Industry Starts With Emotional Intelligence
The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.
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To Make Your Legal Writing Clear, Emulate A Master Chef
To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.
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Trauma-Informed Legal Approaches For Pro Bono Attorneys
As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.
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Using A Children's Book Approach In Firm Marketing Content
From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.
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New Crypto Reporting Will Require Rigorous Recordkeeping
The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.
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Exploring An Alternative Model Of Litigation Finance
A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.