International
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June 13, 2025
Tax Credit Sales Would Be Difficult To Insure Under House Bill
House Republicans' sweeping budget bill proposes to promptly scale back the clean energy tax incentives established by the 2022 climate law, a move that would make it difficult for tax insurers to back project development deals that want to sell their tax credits for cash.
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June 13, 2025
Taxation With Representation: Debevoise, Latham, Paul Weiss
In this week's Taxation With Representation, Brown & Brown Inc. buys Accession Risk Management Group Inc., Allison Transmission Holdings Inc. acquires Dana Inc.'s off-highway unit, Qualcomm Inc. buys Alphawave IP, and Warner Bros. Discovery announced it will split into two publicly traded companies.
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June 13, 2025
Private Schools Lose Bid To Overturn VAT On Fees
The U.K. government has not breached human rights law by extending value-added tax to private school fees, the High Court ruled Friday, rejecting claims brought by a group of schools and families.
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June 12, 2025
Broader German Tax Base Key To Fiscal Growth, OECD Says
Germany should consider multiple avenues to broaden its tax base in the name of ensuring medium-term fiscal stability, the Organization for Economic Cooperation and Development recommended Thursday, saying such changes could also lead to lower labor taxation.
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June 12, 2025
China Agrees To Loosen Rare Earth Restrictions, US Says
Chinese trade negotiators have agreed to lift export controls on rare-earth elements in exchange for the U.S. walking back a campaign to revoke visas for Chinese students, according to statements by U.S. officials, which experts said leave key issues unresolved.
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June 12, 2025
UK Investors Sue Cricket Team Owner Over Claimed Tax Fraud
Three U.K.-based investors in an Indian Premier League cricket team are seeking £10 million ($13.6 million) in damages from the club's owner, claiming in a London court that he duped them over the tax implications of selling their shares in his business.
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June 12, 2025
Customs Missteps Don't Void VAT Exemption, ECJ Says
A horse owner can still claim a value-added tax exemption if she was merely negligent, rather than deceitful, in failing to declare her horses with Swedish customs officials, the European Court of Justice held Thursday.
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June 12, 2025
France Increased Tax Fraud Penalties By €1B In 2024
France's tax authority meted out €16.7 billion ($19.3 billion) in tax fraud duties and penalties in 2024, a €1 billion increase over the year prior, the head of the agency said Thursday.
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June 11, 2025
Russia Must Face $5B Yukos Award Suit, DC Judge Rules
At D.C. federal judge on Wednesday denied Russia's bid to nix litigation filed by the financing arm of Yukos Oil Co. to enforce a nearly $5 billion arbitral award, saying the Kremlin's jurisdictional objections fell short.
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June 11, 2025
US Consultant In France Must Pay $2M In FBAR Penalties
An American energy consultant residing in France must pay more than $2 million in penalties for purposely not disclosing foreign bank accounts that held more than $3 million, as opposed to the under $30,000 initially reported, a D.C. federal court ruled.
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June 11, 2025
House Budget Would Strong-Arm Foreign Gov'ts, Experts Say
The U.S. House-passed budget would discard the tax-exempt status of foreign governments and entities connected to them, such as sovereign wealth funds, and impose escalating tax rates if those countries employ fiscal policies that lawmakers consider unfair, according to several experts.
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June 11, 2025
Senate Dems' Bill Would Bar GILTI For 'Round-Tripped' Income
Income that is "round-tripped" to obtain tax advantages would become ineligible for the half-off corporate tax rate under the global intangible low-taxed income regime, based on a bill introduced Wednesday by Sen. Ron Wyden, D-Ore., and three other Senate Democrats.
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June 11, 2025
Trump Pick For IRS Chief Clears Key Senate Hurdle
President Donald Trump's nominee to serve as commissioner of the Internal Revenue Service survived a key procedural vote Wednesday in the Senate, setting the stage for the chamber to proceed with a final vote on his confirmation.
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June 11, 2025
37% Of Romania Cos. Fall Short On EU Reporting Standard
Almost 40% of businesses filing public country-by-country reports in Romania are failing to fully comply with the European Union's reporting standard, according to a report by a nonprofit organization.
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June 11, 2025
Peru Ratifies OECD Tax Treaty Standards
Peru ratified the Organization for Economic Cooperation and Development's multilateral convention on base erosion and profit shifting, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said Tuesday.
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June 10, 2025
UK Refiner Wins A Round In $200M EU Energy Tax Dispute
An international tribunal has ruled that a British oil refiner's claim challenging a €175 million ($200 million) windfall tax in Europe will proceed without bifurcation, concluding that jurisdictional objections lodged by Germany, Denmark and the European Union should be weighed concurrently with the merits.
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June 10, 2025
Yukos Says $5B Russia Award Suit Must Proceed
Yukos Oil Co.'s financing arm has told a D.C. federal court that a recent U.S. Supreme Court decision rejecting the Ninth Circuit's outlier interpretation of a jurisdictional question moots Russia's request that the court pause enforcement of a $5 billion arbitral award against the country.
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June 10, 2025
Mauritius Budget Proposal Includes Min. Tax, VAT On Digital
African island nation Mauritius is planning to adopt a portion of the OECD's global corporate minimum tax on large multinational entities starting next year and adjust its value-added tax regime to cover foreign digital services.
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June 10, 2025
Fed. Circ. Keeps Trump Tariffs In Place, Fast-Tracks Appeal
The Federal Circuit on Tuesday granted the federal government's bid to keep President Donald Trump's global tariffs in place while it appeals a U.S. Court of International Trade order striking them down on the grounds that they exceeded the president's authority.
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June 10, 2025
Sweden May Exempt Foreign Gov'ts From Dividend Tax
Sweden's Ministry of Finance is considering allowing certain foreign countries to be exempt from the obligation to pay withholding taxes on dividends from Swedish companies and funds following a federal court ruling.
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June 10, 2025
Plastic Waste Often Illegally Burned, Tax Chiefs Say
Plastic waste shipped abroad is often illegally incinerated rather than recycled, including that in Turkey and Indonesia, the Dutch and British tax authorities said Tuesday.
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June 10, 2025
Pros Say OECD Report Spurs Push For Real-Time Monitoring
International tax agencies are focused on harnessing technology, including artificial intelligence, to become more efficient and improve compliance, global tax professionals said Tuesday.
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June 10, 2025
Tax Chiefs Say Flagging Oddities Could Reduce ID Crimes
Flagging suspicious behaviors, like bank accounts receiving multiple tax refund deposits in a matter of days, could help reduce identity-based crimes, a public-private partnership with top tax officials from five countries including the U.S. reported Tuesday.
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June 10, 2025
No Millionaire Exodus Over UK Tax Reform, Report Says
Millionaires are not leaving the U.K. in large numbers because of the burden of high taxes, according to a report published Tuesday by campaign groups.
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June 10, 2025
Flagging Fintech Could Help Stop Tax Crimes, Tax Chiefs Say
Governments could help mitigate money laundering and tax evasion by flagging fintech firms with services nested within traditional banks, with virtual assets used for anonymity or with fiat currency conversion services, top tax officials from five countries including the U.S. said Tuesday.
Expert Analysis
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Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.
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Law Firms Should Move From Reactive To Proactive Marketing
Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.
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The Big Issues A BigLaw Associates' Union Could Address
A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.
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It's Time For A BigLaw Associates' Union
As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.
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How Justices Upended The Administrative Procedure Act
In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.
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Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster
Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.
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Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?
A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.
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3 Leadership Practices For A More Supportive Firm Culture
Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.
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E-Discovery Quarterly: Rulings On Hyperlinked Documents
Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.
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Loper Bright Limits Federal Agencies' Ability To Alter Course
The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.
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After Chevron: Delegation Of Authority And Tax Regulators
The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.
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Lawyers Can Take Action To Honor The Voting Rights Act
As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.
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How To Grow Marketing, Biz Dev Teams In A Tight Market
Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.