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September 04, 2026
Pfizer Can't Cut Ala. Tax With Shuffled Loans, Court Affirms
Pfizer cannot reduce its Alabama corporate income tax liabilities by deducting $658 million in interest payments made to an Irish affiliate that shuffled them to Luxembourg affiliates as tax-free dividends, the Alabama Court of Civil Appeals said Friday, affirming a lower court's decision.
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September 04, 2026
Hong Kong And Slovenia Sign Tax Treaty
Hong Kong and Slovenia signed a tax treaty Friday that would slash withholding tax rates for Hong Kong residents, according to the Inland Revenue Department.
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September 04, 2026
4th Circ. Affirms $2.9M IRS Fine For Unreported Accounts
The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclose offshore accounts to the IRS.
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September 04, 2026
Singapore's Tax Take Rises To $77B, Driven By Biz Tax
Singapore collected 97.3 billion Singapore dollars ($76.8 billion) in tax revenue during its 2025-26 fiscal year, about 9.4% more than the previous cycle, driven by corporate income tax, the country's Inland Revenue Authority said Friday.
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September 04, 2026
Spain Calls For EU Energy Firm Tax To Fund Climate Action
Spain called on the European Union to consider a levy on the profits of oil and gas companies to fund the region's response to the climate crisis, according to a letter and policy paper seen Friday by Law360.
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September 04, 2026
EU Countries Bristle At Tax Avoidance Rule Proposal
European Union member states are concerned that proposed changes to anti-tax avoidance rules, such as those that relate to how much interest companies can deduct from taxable profits, may result in revenue losses and an increased risk of tax abuse, EU officials told Law360 on Friday.
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September 03, 2026
Canadian Group Can't Blend Insurance Businesses' Income
A fraternal benefit society cannot blend its life insurance and accident insurance businesses for tax purposes, Canada's Federal Court of Appeal said, setting aside a lower court's decision.
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September 03, 2026
Australia Floats Bill For 30% Min. Tax On Discretionary Trusts
Australia is seeking feedback on a bill that would create a 30% minimum tax on discretionary trusts to better align tax rates on trust income and employment income, the Department of the Treasury said.
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September 03, 2026
Firm Must Give Client Docs To Tax Agency, Canada Court Says
A Toronto-based accounting firm must hand over client information to the Canada Revenue Agency, a Canadian appeals court ruled, holding that a lower court erred in giving the firm "a second kick at the can" in fighting to withhold documents.
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September 03, 2026
EU Moves To Ease Armenia Tariffs After Russian Restrictions
The European Parliament's International Trade Committee on Thursday advanced a measure that would remove ad valorem duties on a swath of Armenian products to provide aid to the country in the wake of Russian trade restrictions.
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September 02, 2026
Airbnb Can't Nix IRS Expert In $1.3B Bill Fight, Tax Court Says
The U.S. Tax Court denied Airbnb's bid to strike IRS expert witness reports from discovery proceedings in the company's challenge against a $1.3 billion tax bill, ruling Wednesday that a procedural rule governing expert testimony applies only to trials.
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September 02, 2026
German Gov't Backs €10B Tax Break, 'Super-Rich Tax'
Germany's cabinet approved a bill Wednesday that would provide €10 billion ($11.6 billion) in tax relief to low- and middle-income taxpayers, partly funded by adding a 47% top rate for individuals that's been called a "super-rich tax" by the country's Finance Ministry.
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September 02, 2026
Austrian Asset Transfer Meets VAT Exception, EU Court Says
An Austrian man doesn't owe value-added taxes on the transfer of his buildings and other assets to a company he owned, the European Union's top court ruled Wednesday, holding that the transaction falls under an exception in EU VAT law.
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September 02, 2026
Canada Extends Fuel Tax Cut As Wars, Tariffs Drive Up Prices
Canada is prolonging a suspension of its fuel excise tax, citing higher prices driven by wars in the Middle East and Europe as well as U.S. tariffs, the Department of Finance Canada said Wednesday.
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September 02, 2026
HMRC Defeats Shareholder Appeal Over £10M Payout
Britain's tax authority didn't misinterpret tax legislation when it applied anti-avoidance rules to a holding company's payout of £10 million ($13.5 million) to shareholders, a London tribunal ruled Wednesday.
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September 02, 2026
EU Court Backs Partial VAT Clawback on Belgian Business
A Belgian company must repay some of the value-added tax deductions it took for building renovations, the European Union's top court ruled Wednesday, holding that the deductions ceased to be available once the business began leasing its buildings.
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September 02, 2026
Lutnick Says Semiconductor Tariffs Are Coming, With Carveouts
U.S. Secretary of Commerce Howard Lutnick on Wednesday said the U.S. is looking to issue a broad tariff on semiconductors, though he also said it would be structured such that companies that commit to U.S. manufacturing would be exempt.
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September 02, 2026
EU Tax Overhaul Isn't Green Light for Evasion, Official Says
Proposals for European Union tax changes designed to support businesses in the region do not mean the bloc has abandoned its fight against tax evasion, a European Commission official said Wednesday.
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September 02, 2026
OECD Official Presses For EU Biz Tax Regime To Go Further
A European Union proposal to improve the business climate in the bloc could be more effective if it included additional provisions related to research and development and loss-offset rules, a senior figure in the Organization for Economic Cooperation and Development said Wednesday.
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September 01, 2026
Siemens Leaders Testify They Were Unaware Of Tax Strategy
Three executives who described how Siemens' digital software business integrated Mentor Graphics' operations after acquiring that electronic design automation company in 2017 seemed oblivious to the tax aspects of the restructuring that occurred in 2018, their testimony Monday and Tuesday showed.
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September 01, 2026
Investment Co. Disputes IRS' $166M Add-On To Capital Gains
An investment company accused the IRS of mistakenly inflating its 2008 short-term capital gains from certain securities investments to about $170 million from $4 million, telling the U.S. Tax Court the gains were properly deferred during the Great Recession.
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September 01, 2026
Valid Regs Require Abbott To Pay Tax On $8B Gain, IRS Says
The IRS urged the U.S. Tax Court to validate regulations that the agency said required Abbott Laboratories to pay taxes on an $8 billion gain stemming from transactions between its foreign affiliates, arguing the pharmaceutical giant is pushing for "an inappropriately rigid" statutory interpretation.
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September 01, 2026
China Ends Tax Break For Foreign Investor Dividends
Individual foreign investors who receive dividends and bonuses from Chinese companies with foreign capital investments are now liable for a 20% withholding tax on that income, the government said Tuesday, ending a tax break in place since 1994.
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September 01, 2026
UK Maps Out Pension Fund Inheritance Tax Reporting Rules
The U.K. government set out further detail on inheritance tax reporting rules to be rolled out for pension schemes as part of fiscal changes to bring unused pension pots into taxation in April 2027, according to a policy paper.
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September 01, 2026
Sweden To Let Unlisted Cos. E-File Withholding Tax Info
Unlisted Swedish companies that manage their own share registries would be able to file withholding tax information electronically to the Swedish Tax Agency under a bill proposed Tuesday by the Ministry of Finance.
4 Books Transfer Pricing Economists Think You Should Read
What do transfer pricing experts — economists, specifically — do in the summer? In July, many of them attend the National Association for Business Economics' annual transfer pricing symposium and discuss their favorite books with Law360 during the coffee breaks. Others were kind enough to do it during their regular work hours. Here, Law360 looks at four of their picks.
BlueCrest Ruling Sparks Tax Uncertainty For UK Firms
The U.K. Supreme Court's recent ruling that fund managers are taxable as employees rather than partners injects considerable uncertainty into the financial services industry, with companies potentially facing increased scrutiny from tax authorities and less predictable tax obligations.
EU Council OKs Bloc Customs Modernization Program
A suite of changes aimed at modernizing the European Union's customs administration to help it handle the e-commerce boom is on the precipice of implementation after the Council of the EU approved them Thursday, teeing up a final vote in the European Parliament.
Featured Stories
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Reporting Prediction Market Wins A Safe Bet Amid IRS Silence
The IRS has yet to clarify how it will treat money people pocket from trading event contracts on prediction market platforms, but specialists urge against taking the agency's silence as an excuse to omit wins and losses from returns.
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China's Tax Changes Leave Rich Rethinking Wealth Planning
Changes to China's tax treatment of offshore trusts and a wider compliance cleanup have prompted wealthy investors to rethink strategies designed to lower their tax burdens, experts say.
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Int'l Tax In July: New UK PM, Win For Denmark, US Tariff Pivot
New leadership in the U.K. comes with the possibility of higher tax rates for some businesses in light of Prime Minister Andy Burnham's plans to reform the country's healthcare system, while a recent U.K. Supreme Court case could spell good news for Denmark in its long-running battle against cum-ex fraud. Here, Law360 looks at some of July's biggest international tax developments.
Expert Analysis
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Taekwondo Makes Me A Better Lawyer
Taekwondo has taught me to recognize when to fight for a position and when to focus on finding a solution, and that the best outcomes are often achieved by solving problems — all of which has improved my work as a bankruptcy lawyer, mediator and Subchapter V trustee, says Amy Denton Mayer at Berger Singerman.
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OECD Draft Could Guide Pricing For Intragroup R&D Deals
The Organization for Economic Cooperation and Development's proposed revisions to its intragroup transfer pricing guidelines provide helpful tips for determining the cost base for contract research and development services, highlighting the importance of selecting a reasonable set of third-party comparables and appropriate means for evaluating markups, says economist Harold McClure.
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Monitor Exposure, Stay Flexible Amid Tariff Uncertainty
To navigate an unstable trade environment, businesses must evaluate their exposure to new tariffs invoked under a patchwork of statutory authorities and be prepared to adapt to further changes that may be on the horizon, says Bhargav Prajapati at Capital Trade.
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Being In A Band Made Me A Better Lawyer
Playing shows in storied New York City venues and rehearsing with my bandmates in poorly ventilated rooms helped develop the professional qualities I rely on as a litigator, including an ability to collaborate with strong-minded equals and the determination to treat each client with singular focus, says Eliad Shapiro at Herrick Feinstein.
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The Divergent Approaches In US, EU Forced Labor Standards
Forced labor guidance documents recently issued by the U.S. and the European Union have meaningful differences, with the U.S. taking a documentary approach to compliance and the EU emphasizing human rights risks as a governance challenge, but one model will likely exert greater influence, say attorneys at Steptoe.
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Going To Hardcore Shows Makes Me A Better Lawyer
While government contracts law and the hardcore scene may seem entirely unrelated, in my experience, both are about community, focus, being prepared for the unexpected and managing chaos, says Isaac Natter at Fluet.
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Handling Section 301 Tariffs When CBP Detains Goods
Importers subject to Section 301 tariffs on goods under a U.S. Customs and Border Protection forced labor hold should consider three approaches when deciding whether to pay tariffs on goods that may ultimately be excluded, or wait and watch port demurrage compound daily, says James Ferry at Ferry Trade.
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Judges On AI: Examining Administrative, Organizational Uses
U.S. District Judge Alan Albright of the Western District of Texas examines how artificial intelligence could transform a court's ability to deal with administrative work and organize materials when preparing for hearings or drafting opinions, thereby affording judges more time to resolve contested issues.
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Being A Magician Makes Me A Better Lawyer
The skills I've developed as a lifelong magician have translated directly into tangible benefits in the courtroom because performing magic and trying cases both live at the intersection of psychology, storytelling, timing and disciplined rehearsal, says Mark Dombroff at Fox Rothschild.
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Choral Singing Makes Me A Better Lawyer
Singing in the New York City Bar Chorus — a hobby partly inspired by the late U.S. District Judge Richard Owen, who infused my clerkship year with opera music — has improved my legal career by refining my abilities to listen, exude confidence and develop emotional intelligence, says Bonnie Baker at Friedman Kaplan.
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Power To The Paralegals: Burnout As A Structural Problem
Law firm leadership can best retain their paralegals not by encouraging self-care, but by seeking top-down structural solutions for the quiet proliferation of responsibilities and the vicarious exposure to client trauma that particularly drive burnout in this vital role, says Erika Sneeringer at Brockstedt Mandalas.
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Managing Post-IEEPA Tariff Refunds, Replacements And Risks
Companies and investors reeling from the rapid changes resulting from February's U.S. Supreme Court ruling that the International Emergency Economic Powers Act doesn't authorize tariffs should focus on understanding the duty refund process, the likely replacement tariffs and the operational ways they can minimize their tariff exposure, say attorneys at Debevoise.
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Economic Questions To Ask Amid Tariff Refund Class Actions
The U.S. Supreme Court's recent holding that the International Emergency Economic Powers Act doesn't authorize the president to impose tariffs has sparked class actions, but determining whether a retailer received a windfall is complex, even if it passed tariff costs into consumer prices before receiving a refund, say economists at Ankura Consulting Group.