International

  • May 05, 2025

    Co. Urges Ending IRS Cost-Sharing Rule After Justices' Ruling

    A controversial rule requiring U.S. companies to include employee stock-based compensation in cost-sharing agreements with offshore affiliates should be scrapped following the U.S. Supreme Court's revocation of required judicial deference to agencies, a drug distributor told a Texas federal court in seeking a nearly $10 million tax refund.

  • May 05, 2025

    Novelist Owes $715K In FBAR Penalties, US Says

    A Japanese author with U.S. citizenship faces penalties exceeding $715,000 for failing to report accounts she held at a Swiss bank, the U.S. government told a California federal court.

  • May 02, 2025

    UK Customs Co. Liable For £1.1M VAT Bill, Tribunal Says

    A U.K. company responsible for getting goods through customs must split a £1.1 million ($1.3 million) value-added tax bill that an importer deferred before going out of business, the First-tier Tribunal ruled.

  • May 02, 2025

    US, China Battling Over Entrenched Economies, Experts Say

    Differing economic philosophies are contributing to the escalating trade war between the United States and China, according to professionals who follow the countries' relations, with the Chinese government's supply-side ideology rooted in exports and U.S. deficit spending driving demand for imports.

  • May 02, 2025

    Money Laundering, Tax Charges Nixed Vs. Crypto Operator

    An Indiana federal judge dismissed the U.S. government's cases against a man accused of operating an unlicensed money transmitting business, laundering proceeds through cryptocurrency transactions and failing to file tax returns after finding his business was not subject to registration requirements, as the government had maintained.

  • May 02, 2025

    Glencore Exec Can't Duck Tax On £150M In Offshore Shares

    Glencore's former head of oil failed to overturn a finding he was liable for income tax on nearly £150 million ($200 million) in share distributions from the Jersey-incorporated company, when an appeals court concluded Friday it was subject to U.K. taxation.

  • May 02, 2025

    IRS Updates Rates For Foreign Insurance Company Equations

    The Internal Revenue Service on Friday published updated domestic asset/liability and yields percentages for 2024 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.

  • May 02, 2025

    Taxation With Representation: Goodwin, Haynes Boone

    In this week's Taxation With Representation, Merck buys SpringWorks Therapeutics, Novartis AG acquires Regulus Therapeutics Inc., Sabre Corp. sells its Hospitality Solutions business to private equity shop TPG, and TWG Global and Mubadala Capital team up to bolster their investments.

  • May 02, 2025

    Community Groups Accept Pause In CTA Litigation

    A group of community associations has told the Fourth Circuit they aren't opposed to a government motion to pause litigation over the Corporate Transparency Act, even as they maintained the information disclosure law aimed at small businesses still carries constitutional flaws.

  • May 01, 2025

    Irish Tax Appeals Board Closed €355M In Cases In 2024

    Ireland's Tax Appeals Commission closed more than 1,711 appeals cases in 2024, a 12% increase over the year prior and valued at €355 million ($401 million) in taxes, the commission said in a report.

  • May 01, 2025

    Multinationals Grapple With Tariff-Induced Pricing Issues

    President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.

  • May 01, 2025

    Trump Picks Tax Controversy Pro For IRS Chief Counsel Spot

    President Donald Trump has tapped a former Internal Revenue Service chief counsel to return to the role, and if he is confirmed, it will represent the second time in his career that the veteran tax controversy professional will be the agency's top attorney.

  • May 01, 2025

    Chilean Digital Platforms Must Show Users' Tax Compliance

    Digital platforms operating in Chile will need to show that those either contracting their services or using them to offer their owns goods and services are tax-compliant starting in 2026, Chile's tax administration said.

  • May 01, 2025

    Canada Looks To Guide Exporters Navigating US Tariffs

    The Canadian government is offering new resources for exporters dealing with what it called unjustified U.S. tariffs, providing information on rules of origin and customs procedures under the U.S.-Canada-Mexico Agreement.

  • May 01, 2025

    Estate Pushes Back On IRS In DC Circ. Lost Records Case

    The estate of a man whose offshore businesses were raided by the IRS, giving rise to a nearly $18 million tax judgment, criticized the agency's effort to rebuff the estate's claims to the D.C. Circuit that the IRS fraudulently claimed that boxes of evidence in ensuing litigation were lost.

  • May 01, 2025

    Ore. Tax Court Retains Nix Of Microsoft Foreign Income Relief

    The Oregon Tax Court is adhering to its finding on the treatment of Microsoft's repatriated foreign income when calculating its state income, making only minor changes to an earlier order and rejecting the company's arguments for further relief.

  • May 01, 2025

    ECB Says Consumers Ready To Avoid US Goods Over Tariffs

    European consumers are prepared to avoid American goods for the long term, following the impact of tariffs imposed by the U.S. administration, according to a survey by the European Central Bank.

  • May 01, 2025

    BNY Can't Escape A&O Shearman's £93M Negligence Claim

    Bank of New York Mellon lost its fight Thursday to escape a claim from Allen Overy Shearman Sterling alleging that the lender caused Nationwide Building Society to face a £93 million ($109 million) tax bill by bungling the issuance of notes.

  • April 30, 2025

    Senate Rejects Bill To End Trump's Nat'l Emergency On Tariffs

    The U.S. Senate narrowly rejected a bipartisan bill Wednesday that sought to end the national emergency declared by President Donald Trump to underpin his global tariff regime, with two senators absent for the vote, and with U.S. House consideration delayed until October.

  • April 30, 2025

    Workers' Effective Tax Rates In OECD Up Again, But So Is Pay

    While the effective tax rates on labor across the Organization for Economic Cooperation and Development's 38 member countries on average ticked up for a third year in a row in 2024, average wages were up in all but four countries after dropping over the prior two years, the OECD said Wednesday.

  • April 30, 2025

    US Economy Shrank 0.3% In First Quarter As Imports Surged

    U.S. gross domestic product fell at an annual rate of 0.3% in the first quarter of 2025 as importers stockpiled goods in advance of President Donald Trump's global tariff regime, the U.S. Department of Commerce announced Tuesday.

  • April 30, 2025

    EU Busts $10M VAT Fraud Ring Involving Chinese Imports

    The European Anti-Fraud Office and Polish authorities uncovered a value-added tax fraud ring that exploited European Union rules to dodge over 38.2 million Polish zloty ($10.1 million) in value-added taxes on goods imported from China, they said Wednesday.

  • April 30, 2025

    Morgan Lewis Expands Tax Practice With Milbank Hire

    Morgan Lewis & Bockius LLP added a former Milbank special counsel as a tax partner based in the firm's London office.

  • April 30, 2025

    Dentist Fights HMRC Over Alleged Tax Avoidance

    A dentist's firm urged an appeals court on Wednesday to find that it had not engaged in tax avoidance by making loan payments to its owner through a trust, saying the payments had no connection to its owner's employment and therefore were not taxable as income.

  • April 30, 2025

    Switzerland Begins Consultation On Pillar 2 Return Rules

    The Swiss government said Wednesday that it has begun the consultation process to create compliance rules for a global information return that companies must submit as part of an international minimum corporate tax agreement known as Pillar Two.

Expert Analysis

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

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