International
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October 08, 2025
Crypto Debt Securities Open To Retail Investors, HMRC Says
U.K. retail investors now can include in their tax-advantaged savings accounts debt securities related to crypto-assets, which were previously limited to professional investors, HM Revenue & Customs announced Wednesday.
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October 08, 2025
Tobacco Co. Made Timely Tax Refund Claims, UK Court Rules
A British tobacco company didn't wait too long to seek repayment of taxes it mistakenly paid on foreign dividends, a U.K. appeals court ruled Wednesday, rejecting HM Revenue & Customs' contention that the claims were time-barred.
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October 08, 2025
Greece To Face CJEU Over Tax-Free Shops' Excise Exemption
Greece has continued to flout the European Union's rule against excise duty exemptions for goods sold at tax-free shops at borders with non-EU countries, the European Commission said Wednesday, announcing that it had referred the country to the Court of Justice of the European Union.
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October 08, 2025
Denver Attorney Returns To Reed Smith State Tax Team
Reed Smith is expanding its tax practice with the return of an experienced attorney, now based in Denver, with multistate experience in the full spectrum of tax issues.
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October 08, 2025
Charity Gifts In Wills Hit £1B As Estates Swerve Tax Bills
The value of charitable gifts left in people's wills climbed to £980 million ($1.3 billion) in the last financial year to April, as more Britons used philanthropy to reduce inheritance tax bills, London law firm TWM Solicitors LLP said Wednesday.
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October 07, 2025
11th Circ. Wary Of IRS Procedure In FBAR Penalty Appeal
An Eleventh Circuit panel Tuesday appeared concerned about IRS procedures that could keep a man from recouping $419,000 he paid to resolve his failure to disclose funds held in foreign bank accounts as he appeals a district court determination that he actually owes $2.2 million.
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October 07, 2025
Senate OKs Top Treasury Atty Pick In Slate Of Confirmations
The Senate approved President Donald Trump's choice of a Sidley Austin LLP partner to be general counsel of the U.S. Department of the Treasury on Tuesday as part of a combined confirmation of 108 nominees to various roles.
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October 07, 2025
German States Vote Against Suspending Global Minimum Tax
A majority of Germany's states voted against a motion to suspend the 15% global minimum tax while the international community is resolving a U.S. proposal to exempt American companies from most of the system, two state finance ministries told Law360 on Tuesday.
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October 07, 2025
Ireland Plans To Revise Laws On Tax Breaks For Interest
Ireland's Finance Department is working on an overhaul to laws covering tax deductions for interest, it announced Tuesday, saying it expects to submit amendments to lawmakers next year that focus on areas like aligning the tax treatment of foreign interest income from trading and passive sources.
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October 07, 2025
IRS Provides Grace Period For Int'l Money Transfer Tax Errors
U.S. financial institutions that handle overseas money transfers won't immediately face penalties if they fail to accurately deposit new excise taxes that are required under the budget reconciliation bill enacted in July, the Internal Revenue Service announced Tuesday.
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October 06, 2025
Fed. Circ. Partially Revives German Steel Co.'s Dumping Suit
The U.S. Commerce Department cannot use a German steelmaker's likely sales prices as a proxy for the cost of producing nonprime steel plates, but the company acted too late to argue for categorizing some plates separately as it challenges Commerce's antidumping investigation, the Federal Circuit said Monday.
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October 06, 2025
IRS Cyber Crime Executive Named Interim Compliance Chief
An Internal Revenue Service criminal investigations executive who founded the division's cyber crimes sections will temporarily take on an elevated role overseeing all agency enforcement operations, the IRS announced Monday.
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October 06, 2025
Italian Police Seize Assets In Suspected €43M Car VAT Fraud
Italian police seized cars, bank accounts, real estate and luxury goods connected to a suspected scheme to evade nearly €43 million ($50 million) in value-added taxes on luxury cars imported from Germany, the European Public Prosecutor's Office said Monday.
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October 06, 2025
London Casino Loses Dispute Over VAT Base Method
HM Revenue & Customs used the correct method for calculating the value-added tax base of a casino, a London court ruled Monday, rejecting the casino's arguments for the use of a special method that would have allowed it to recover more input VAT.
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October 06, 2025
Social Security Chief Adds Duties As Inaugural CEO Of IRS
The current administrator of the Social Security Administration is adding a new role as the Internal Revenue Service's first chief executive officer, Treasury Secretary Scott Bessent announced Monday.
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October 03, 2025
28% Of Large Cos. In Australia Paid No Income Tax Last Year
The share of large companies operating in Australia that paid no income taxes dropped below 30% for the first time during the 2023-2024 period, the Australian Taxation Office said, attributing this to officials curbing tax avoidance.
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October 03, 2025
Indian Gov't Report Floats Fixed Profit Rates For Foreign Cos.
India should revise its permanent establishment rules by introducing an optional scheme to assign fixed profit rates by industry or business model, which would reduce litigation by foreign businesses over profit attribution methods, a government think tank said Friday.
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October 03, 2025
Some Longtime Legal Blogs Go Quiet As Platform Shuts Down
When the online publishing platform Typepad launched more than two decades ago, it became a hub for a then-growing community of law professors and legal bloggers. Its closure this week marked the end of an era that has found some bloggers looking for new homes or opting to call it quits.
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October 03, 2025
DC Circ. Split On Challenge To IRS-ICE Info-Sharing Deal
D.C. Circuit judges seemed split Friday over whether an information-sharing agreement between immigration authorities and the IRS complies with taxpayer privacy protections, with one judge noting during oral arguments that the government immigration arm requesting the tax information appears unauthorized to make the requests.
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October 03, 2025
Getting It Right: An Economist On Transfer Pricing
Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.
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October 03, 2025
Mining Cos. Warn Of OECD Guidance's Transfer Pricing Risks
Mining companies and other stakeholders raised concerns over transfer pricing risks and possible tax disputes arising from proposed guidance on pricing copper exports, according to documents published by the Organization for Economic Cooperation and Development.
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October 03, 2025
Taxation With Representation: Kirkland, Paul Weiss, Cravath
In this week's Taxation With Representation, video game maker Electronic Arts agrees to be acquired by the Saudi Arabia Public Investment Fund, Silver Lake and Affinity Partners; online mortgage giant Rocket closes its acquisition of rival Mr. Cooper Group; and Berkshire Hathaway acquires international energy company Occidental's chemical business.
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October 03, 2025
Denmark's £1.4B Cum-Ex Loss Raises Legal Strategy Doubts
Denmark's "bruising" defeat in its £1.4 billion ($1.9 billion) cum-ex fraud case against trader Sanjay Shah and others calls into question its legal strategy and the scope of its claim, lawyers have said, although they believe an appeal appears inevitable.
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October 03, 2025
Denmark Denied Permission To Appeal £1.4B Cum-Ex Defeat
Denmark cannot revive its £1.4 billion ($1.9 billion) against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.
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October 02, 2025
IRS Data-Sharing Case Won't Be Paused For Gov't Shutdown
The U.S. Department of Justice must still submit court-ordered information in a lawsuit challenging the Internal Revenue Service's sharing of tax data with immigration authorities by Oct. 24, a D.C. federal judge ruled, despite the federal government shutdown that began Wednesday.
Expert Analysis
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.
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8 Childhood Lessons That Can Help You Be A Better Attorney
A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.
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This Election, We Need To Talk About Court Process
In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.
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Mental Health First Aid: A Brief Primer For Attorneys
Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.
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The Trade And Tax Issues Behind US-Canada Digital Tax Clash
The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.