International
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June 18, 2025
Fed. Circ. OKs How Commerce Filled Blank In Steel Duty Case
The U.S. Department of Commerce may apply adverse facts to a company that fails to propose reasonable alternatives for collecting information that would be unreasonably hard to obtain in an antidumping investigation, the Federal Circuit said in a precedential opinion upholding steel duties on German companies.
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June 18, 2025
£20M Buybacks Weren't Mainly For Tax Benefit, UK Court Says
Obtaining a tax advantage wasn't the main purpose of two businessmen arranging £20 million ($26.8 million) in share buybacks, despite that being the effect, so they aren't liable for an anti-avoidance action by HM Revenue & Customs, the U.K. Upper Tribunal said in overturning a lower court's ruling.
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June 18, 2025
Billabong Founder Must Split Costs In AU$50M Tax Bill Loss
The founder of surf brand Billabong and the Australian tax authority must split the costs of litigation that ultimately put the founder on the hook for AU$50 million ($33 million) in taxes, the Federal Court of Australia held Wednesday.
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June 18, 2025
Mich. Housing Co-Op Suit On Hold After Disclosure Exemption
A Michigan federal judge hit pause on a lawsuit from a group of housing cooperatives to escape requirements of the Corporate Transparency Act after the Financial Crimes Enforcement Network said it would give U.S.-based entities a break from the rules.
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June 18, 2025
EU Refers Portugal To Court Over Excise Duty Harmonization
Portugal is three-and-a-half years late in transposing a pair of European Union directives related to excise duties into domestic law, the European Commission said Wednesday, referring the country to the European Court of Justice to face a potential fine, among other announced infringement decisions.
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June 17, 2025
Wyden Vows To Fight For Energy Credits Facing GOP Repeal
The top Senate Democratic tax writer vowed Tuesday to try to protect clean energy tax provisions of the 2022 Inflation Reduction Act that would face an early repeal under the sweeping tax and budget legislation released by Republicans in the Senate Finance Committee.
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June 17, 2025
AbbVie Can Get Deduction For $1.6B Payment, Tax Court Says
AbbVie can claim a deduction for the $1.6 billion it paid under a merger agreement, the U.S. Tax Court held Tuesday, rejecting the IRS' contention that the payment was a capital loss that raised the pharmaceutical giant's tax bill by $572 million.
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June 17, 2025
Ill. Toy Makers Seek Justices' Early Review Of Trump Tariff Suit
Illinois-based toy makers challenging President Donald Trump's emergency tariffs on Tuesday requested the U.S. Supreme Court consider their case before it is reviewed by the D.C. Circuit, arguing a stay to an injunction is allowing duty collections to continue and is damaging the companies.
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June 17, 2025
DOJ Seeks 5 Years, $10M For Fla. Man Hiding Swiss Accounts
A Miami man who lied to authorities and others for decades about his Swiss bank accounts should pay $10.3 million in unpaid taxes and face a maximum five-year prison sentence based on his plea agreement, the U.S. Department of Justice told a Florida federal court.
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June 17, 2025
Poland Calls For EU Digital Services Tax In Revenue Package
The European Commission should consider previous proposals for a digital services tax regime across the European Union as part of its revenue package, the Polish presidency of the Council of the EU said in a report.
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June 17, 2025
Tax Admins In OECD Group Largely Using AI, Report Says
Of the 54 members of the OECD's Forum on Tax Administration, over 70% are using artifical intelligence in some way to improve services, most often to detect tax evasion and fraud, the OECD said in a report Tuesday.
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June 17, 2025
IRS Updates Prefiling Program For Large Biz, Int'l Taxpayers
The Internal Revenue Service has made several changes to its prefiling agreement program, including updating the guidelines to help large corporate and international taxpayers flag potential issues before submitting returns, the agency said Tuesday.
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June 17, 2025
Swedish Tax Agency Asks For Greater Enforcement Powers
The Swedish Tax Agency is looking to enhance its ability to address tax crimes, it told the country's Ministry of Finance on Tuesday, sharing proposals that would strengthen its law enforcement powers and grant it the power to store biometric data.
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June 17, 2025
Norway Looks To Adopt Updated Pillar 2 Guidance
The Norwegian Ministry of Finance proposed updating its adoption of the Organization for Economic Cooperation and Development's global minimum tax to integrate administrative guidance issued over the past year.
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June 17, 2025
HMRC Challenges Tax Treatment Of Partnership Awards
HM Revenue & Customs told the U.K. Supreme Court on Tuesday that partnership awards allocated to a corporate entity and then distributed to partners should be taxed as if they were allocated to individual members.
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June 16, 2025
US, UK Reach Trade Deal On Cars; Steel Tariffs Still Unresolved
President Donald Trump signed an order Monday enshrining the nation's new trade deal with U.K. governments under which the U.S. agreed to slash tariffs on 100,000 imported U.K. automobiles and auto parts, while eliminating tariffs on certain aerospace products but leaving steel and pharmaceuticals tariffs for future negotiations.
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June 16, 2025
Senate Bill Sticks With TCJA's $10,000 SALT Cap
The Senate Finance Committee's tax portion of the chamber's budget reconciliation bill released Monday follows the House's lead on some provisions while breaking with the lower chamber's hard-won compromises on an increased state and local tax deduction and the phaseout of green energy credits.
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June 16, 2025
The Tax Angle: EITC Audits, UTPR, Energy Credits
From a look at Republicans' efforts to audit the earned income tax credit, complaints about unfair foreign taxation under the OECD's Pillar Two framework and Democrats' push against Republican plans to strip the Inflation Reduction Act's energy credits from the code, here's a peek into a reporter's notebook on a few developing tax stories.
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June 16, 2025
Book Profits Much Higher Than Taxable Income, Paper Says
Companies report about three to four times higher profits on financial statements for investors compared with the taxable income they report to authorities, a phenomenon most prevalent among multinational corporations, which suggests book profits underestimate profit shifting, the EU Tax Observatory said Monday.
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June 16, 2025
G7 Could Raise $214B Yearly From 2% Wealth Tax, Group Says
The Group of Seven countries could raise $214 billion a year if each government imposed a 2% wealth tax on fortunes above $100 million, with the U.S. potentially raising $161 billion by itself, a group of wealthy Canadians said Monday in support of such measures.
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June 16, 2025
Trump Eyes Trade Deal With Canada During G7 Summit Talks
President Donald Trump said at the G7 summit Monday that he would work with Canadian Prime Minister Mark Carney to reach a trade deal, raising the possibility that an agreement could be struck before the multilateral meeting concludes.
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June 16, 2025
Wealth Taxes, End Of Profit Shifting Worth $2.6T, Group Says
World governments could raise about $2.6 trillion annually, more than enough revenue to finance most climate-related needs, if they collectively adopted low-rate wealth taxes beginning with the richest 0.5% and stopped multinational corporations from shifting profits, the Tax Justice Network said Monday.
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June 16, 2025
HMRC Warns Umbrella Co. Employees Of Tax Risks
Employees and contractors of temporary worker agencies known as umbrella companies need to be vigilant to make sure they aren't unwittingly involving themselves in tax avoidance schemes, HM Revenue & Customs said, laying out ways to spot such avoidance issues.
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June 16, 2025
OECD Offers Template For Tax Crime Investigation Guidance
The Organization for Economic Cooperation and Development released standards Monday for jurisdictions to use when creating manuals to guide government agencies through tax crime investigations, with the aim of creating more efficient and effective processes, it said.
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June 16, 2025
Colombian Taxpayers Owe $34M In Foreign Exchange Debts
Nearly 290 Colombian taxpayers have accumulated roughly 142.2 billion Colombian pesos ($34.6 million) in unpaid tax debts related to their foreign exchange transactions, the country's tax authority said, offering possible reductions for their associated penalties.
Expert Analysis
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
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E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
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A Cold War-Era History Lesson On Due Process
The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.
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How BigLaw Executive Orders May Affect Smaller Firms
Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.
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Lawsuits Shouldn't Be Shadow Assets For Foreign Capital
Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.