International
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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.
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June 10, 2025
DHL British Unit On Hook For £3M In Duties, Court Says
A tax tribunal did not err when it upheld HM Revenue & Custom's decision to deny about £3 million ($4 million) in duty relief to cargo aircraft operated by DHL's British affiliate, a U.K. court said, dismissing the company's appeal.
Expert Analysis
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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.
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Rock Climbing Makes Me A Better Lawyer
Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.
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Contract Disputes Recap: Preserving Payment Rights
Stephanie Magnell and Zachary Jacobson at Seyfarth examine three recent decisions that together illustrate the importance of keeping accurate records and adhering to contractual procedures to avoid inadvertently waiving contractual rights to cost reimbursements or nonroutine payments.
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Think Like A Lawyer: Dance The Legal Standard Two-Step
From rookie brief writers to Chief Justice John Roberts, lawyers should master the legal standard two-step — framing the governing standard at the outset, and clarifying why they meet that standard — which has benefits for both the drafter and reader, says Luke Andrews at Poole Huffman.
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Lead Like 'Ted Lasso' By Embracing Cognitive Diversity
The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.
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Now More Than Ever, Lawyers Must Exhibit Professionalism
As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.
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Reading Between The Lines Of Justices' Moore Ruling
The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.
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A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates
Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.
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States Should Loosen Law Firm Ownership Restrictions
Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.
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After Chevron: Uniform Tax Law Interpretation Not Guaranteed
The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.
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Texas Ethics Opinion Flags Hazards Of Unauthorized Practice
The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.
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How To Clean Up Your Generative AI-Produced Legal Drafts
As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.