International
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December 22, 2025
Top Federal Tax Policies Of 2025
The first year of President Donald Trump's second term brought the passage of this summer's budget reconciliation bill, which renewed major parts of the 2017 Tax Cuts and Jobs Act, and major staffing changes at the Internal Revenue Service. Here, Law360 looks at the most consequential developments in federal tax policy in 2025.
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December 22, 2025
Tariff Refunds Would Be 'A Mess,' Economic Official Says
It would be an "administrative problem" to issue tariff refunds in the aftermath of a potential U.S. Supreme Court ruling against the White House's trade measures, a top economic policy official said.
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December 22, 2025
IRS Seeks Input On Updates To Voluntary Disclosure Process
The Internal Revenue Service asked Monday for comments on a proposed change to its voluntary disclosure program that would require payment of all taxes, penalties and interest within three months after being conditionally approved for the program.
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December 19, 2025
EU High Court Advised To Force Portugal To Reclaim Taxes
The European Union's top court should rule that Portugal can't allow tax enforcement proceedings to be suspended in the case of unlawful state aid granted by the Madeira Free Zone, an adviser to the court said.
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December 19, 2025
Trade Court Remands Canada Lumber Duty Calculation Again
The U.S. Commerce Department again failed to sufficiently justify how it calculated a subsidy rate in an antidumping duty administrative review for a Canadian exporter of softwood lumber products, the U.S. Court of International Trade said.
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December 19, 2025
Taxation With Representation: Baker Botts, Morgan Lewis
In this week's Taxation With Representation, Trump Media and Technology Group merges with fusion power company TAE Technologies, pharmaceutical company Cencora boosts its stake in cancer care company OneOncology, and Phoenix Financial partners with private equity giant Blackstone to plug billions into various credit strategies.
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December 19, 2025
Calif. Ex-Customs Broker Sentenced For Tax, Wire Fraud
A California man was sentenced to 51 months in federal prison after being indicted this year on federal fraud charges and one count of tax evasion, the U.S. Department of Justice said.
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December 19, 2025
Polsinelli Lands Glaser Weil Tax Pro In Los Angeles
Polsinelli PC is expanding its business team, bringing in a tax pro from Glaser Weil as a shareholder in its Los Angeles office.
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December 18, 2025
Czech Republic, Estonia Shift To Backing Min. Tax Deal For US
The Czech Republic and Estonia have shifted to supporting the proposed U.S. exemption from the global minimum tax's international provisions at the global tax policymaking body hosted by the Organization for Economic Cooperation and Development, the countries' finance ministries told Law360.
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December 18, 2025
Australia Issues Guidance On Min. Tax For Merged Accounts
Australia's tax authority released several guidance documents detailing how the global minimum tax interacts with separate laws on accounting consolidation for corporate groups, as well as issues related to mismatched fiscal years among constituent entities.
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December 18, 2025
Denmark Files To Appeal £1.4B Cum-Ex Fraud Case Defeat
Denmark has launched its effort to revive its £1.4 billion ($1.8 billion) case over a tax fraud allegedly orchestrated by convicted hedge fund trader Sanjay Shah, according to court filings seen by Law360 Thursday.
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December 18, 2025
HMRC Wins Burden Of Proof Query In £54M Tax Fraud Case
A London appeals court ruled Thursday that HM Revenue & Customs doesn't bear the burden of proof in its tax liability claim against a British businessman it alleges used a company to commit alcohol smuggling and tax evasion of over £54 million ($72.2 million), plus penalties.
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December 17, 2025
Court Remands Commerce Ruling On Vietnam Steel Duties
The U.S. Department of Commerce did not properly substantiate its 2023 findings that imports of Vietnamese steel products were flouting duties imposed on South Korea, India and China, the U.S. Court of International Trade said, remanding the agency's determinations.
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December 17, 2025
Ex-Biden Tax Counsel To Chair Willkie Tax Resolution Team
Willkie Farr & Gallagher LLP has hired a former senior tax counsel who worked in two Democratic presidential administrations to come on board as chair of the firm's tax resolution practice group, according to a Wednesday announcement.
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December 17, 2025
EU Looking To Merge Tax Directives Into Single Instrument
The European Commission is considering consolidating the nine bloc directives on administrative taxation cooperation — which cover such areas as the Organization for Economic Cooperation and Development's global minimum tax, crypto-asset reporting and cross-border tax rulings — into one legal instrument.
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December 17, 2025
Treasury Issues Final Rule On BEAT For Securities Lending
Taxpayers must determine and account for certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax, according to a final rule released Wednesday by the U.S. Department of the Treasury.
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December 17, 2025
EU Looks To Expand CBAM To Machinery, Other Products
The European Union has proposed expanding its carbon border adjustment mechanism beyond basic materials to cover certain steel- or aluminum-intensive products like machinery and appliances, saying it wants to prevent spurring emissions-heavy production outside the bloc.
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December 17, 2025
Brazil's New Dividend Tax Rules To Impose 10% Withholding
Dividends and profits paid by Brazilian entities to nonresidents will generally be subject to a 10% withholding tax starting in the new year, the country's revenue agency said in recent guidance, adding that 2025 distributions must be approved before the end of this year to avoid the new tax.
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December 17, 2025
Tax Authorities Shared Data 5,500 Times In 2024, OECD Says
Tax authorities exchanged information on tax rulings 5,500 times last year as part of the base erosion and profit-shifting rules developed by the Organization for Economic Cooperation and Development, according to a report published Wednesday.
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December 17, 2025
UK Supreme Court Tosses Hotel's Atty Fee VAT Appeal
A hotel company can't reclaim value-added tax paid on fees to lawyers and accountants as part of selling a subsidiary to finance the opening of a new hotel, the U.K. Supreme Court ruled Wednesday.
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December 16, 2025
Corporate Transparency Act Is Constitutional, 11th Circ. Says
The Corporate Transparency Act is constitutional because it regulates economic activities with a substantial impact on interstate commerce and doesn't violate protections against unreasonable searches, the Eleventh Circuit said Tuesday, reversing a lower court's decision.
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December 16, 2025
Developing Nations Expand Corporate Tax Breaks, OECD Says
Low- and middle-income countries generally expanded corporate tax incentives in 2024, while some coupled those measures with tax increases, the OECD reported Tuesday.
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December 16, 2025
Fired Top Antitrust Official Warns Of 'Politicization'
The former No. 2 at the U.S. Department of Justice's Antitrust Division until he was terminated this year testified Tuesday about the "politicization" of antitrust enforcement.
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December 17, 2025
CORRECTED: Trade Court Nixes Injunction In Trump Tariff Suit
The U.S. Court of International Trade has denied a preliminary injunction in a suit challenging President Donald Trump's emergency tariffs after auto part retailers failed to convince the court that the relief was necessary to preserve their potential right to refunds.
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December 16, 2025
Morrisons Owes £17M VAT On Chicken Sales, Tribunal Rules
A London tribunal ruled that WM Morrison Supermarkets should have paid £17 million ($22.8 million) value-added tax on rotisserie chickens because the product qualifies as "hot food."
Expert Analysis
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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.
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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.