International
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July 21, 2025
Family Claims Bad Tax Advice Led To Costly HMRC Bills
The trustees of family trusts accused a U.K. accounting firm of giving them negligent advice that led to unexpected inheritance taxes and penalties owed to HM Revenue & Customs, according to a claim filed in a London court.
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July 21, 2025
UK Launches Online Service Available For 35M Taxpayers
HM Revenue & Customs launched an online Pay As You Earn portal Monday, available to 35 million U.K. taxpayers, that the British revenue agency said is intended to make it easier to check on tax information as part of HMRC's overall digital transformation.
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July 21, 2025
Paul Hastings Boosts Tax Team In NY With Ex-Kirkland Atty
Paul Hastings LLP announced Monday that a former Kirkland & Ellis LLP attorney is bringing her tax practice to its New York office in a move the firm says will bolster its ability to guide clients through complex deals like mergers, acquisitions and private equity transactions.
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July 18, 2025
Law360 Names 2025's Top Attorneys Under 40
Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age.
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July 18, 2025
Trade Legal Matters To Watch: Midyear Report
Aggressive, sweeping tariff actions have defined the first six months of President Donald Trump's second term, altering the global trade environment in attempts to return manufacturing to the U.S. and reset trading deficits, but legal challenges to certain duties may obstruct Trump's long-term trade strategy in ongoing negotiations later this year.
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July 18, 2025
HMRC Urged To Broaden Reporting Of Uncertain Tax Positions
HM Revenue & Customs may need to change its rules for when taxpayers must disclose uncertain tax positions they've taken to the tax authority, according to a report by a nonprofit research organization.
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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.
Expert Analysis
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Adapting To Private Practice: From DOJ Leadership To BigLaw
The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.
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How The CRE Industry Is Adapting To Tariff Uncertainty
Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.
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Law Firm Executive Orders Create A Legal Ethics Minefield
Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.
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Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike
The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.
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Firms Must Embrace Alternative Billing Models Or Fall Behind
As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.
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How Attorneys Can Master The Art Of On-Camera Presence
As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.