International
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November 20, 2025
EU Council Approves Tax Deal Changes With 5 States
The Council of the European Union said Thursday that it has approved updates to tax agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland, including new rules to help prevent tax evasion and fraud.
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November 19, 2025
Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real
A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.
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November 19, 2025
Tax Court Upholds Rejection Of Tax Tipster's Award
The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday.
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November 19, 2025
Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty
Governments expressed widespread support for adopting measures to strengthen the mutual agreement procedure within a protocol on dispute resolution in the United Nations tax convention during the latest round of negotiations.
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November 19, 2025
Tax Court Substance Ruling Offers Silver Lining For Taxpayers
Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions.
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November 19, 2025
OECD Releases Model Tax Treaty Updates For Amount B
The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B.
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November 19, 2025
EU Tax Compliance Rules Raise €6.8B Annually, EC Finds
The European Union's directive for administrative cooperation in taxation, known as DAC, has helped tax authorities generate €6.8 billion ($7.8 billion) a year in extra revenue, the European Commission said in a report Wednesday.
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November 19, 2025
Trump's Global Tariffs Curtailed Trade, Data Shows
U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.
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November 18, 2025
Korea Wins Annulment Of $216M Lone Star Funds Award
South Korea on Tuesday prevailed in its bid to wipe out a $216 million arbitral award issued to an affiliate of Lone Star Funds, though the private equity firm has already vowed to resubmit its claim to a new tribunal.
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November 18, 2025
Malawi Reiterates Bid For Gem Export Tax Investigation
Malawi has bolstered its bid for a Washington federal judge to reconsider his decision barring the country from pursing discovery against a gemstone company that partnered with a mining outfit the country claims dodged billions of dollars in taxes and export royalties.
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November 18, 2025
French Inheritance Tax Break Grew To €5.5B, Auditor Finds
The French government's inheritance tax break for family-owned businesses needs to be overhauled as the cost surged to more than €5.5 billion ($6.4 billion) last year, the state auditor said Tuesday.
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November 18, 2025
Tax Return Preparer Gets 18 Months For $25 Million Fraud
A California tax return preparer who admitted he participated in a scheme that claimed $25 million in false refunds was sentenced to 18 months in prison by a California federal court, the U.S. Department of Justice said.
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November 18, 2025
Checklist Could Help Simplify Global Tax Policy, OECD Says
A checklist of questions for global tax policymakers could help simplify the outcomes of their work, the OECD said in a Tuesday report to the Group of 20 nations.
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November 17, 2025
Judge Questions Eaton's Role In Lowered Credit Rating
Tax Court Judge Albert Lauber questioned an expert for Eaton on Monday about how he arrived at a lowered credit rating for the U.S. company in a report he prepared in January 2013, shortly after it acquired an Irish-based global electrical products manufacturer and inverted.
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November 17, 2025
Ex-Russian Gas CFO Resentenced To 6 Years For Tax Crimes
A Florida federal judge handed a nearly six-year prison term to a Russian gas company's former chief financial officer, who was convicted for tax evasion after the Eleventh Circuit vacated a prior sentence earlier this year.
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November 17, 2025
Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free
A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International Trade's decision in a decade-old dispute.
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November 17, 2025
OMB Reviewing Treasury Regs On OECD Crypto Reporting
The Office of Management and Budget is reviewing regulations proposed by the U.S. Department of the Treasury to implement automatic exchanges of information between tax authorities regarding taxpayers' cryptocurrency holdings under the OECD's crypto-asset reporting framework.
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November 17, 2025
MVP: Sullivan & Cromwell's Isaac Wheeler
Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Tishman Speyer on its $3.5 billion refinancing of Rockefeller Center, earning him a spot as one of the 2025 Law360 Tax MVPs.
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November 17, 2025
Fed. Circ. Backs Commerce To Nix Turkish Steel Duties
The U.S. Department of Commerce's removal of countervailing duties on Turkish steel imports was properly justified by the government, and the lower trade court correctly upheld its determination despite objections by the domestic steel industry, the Federal Circuit affirmed Monday.
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November 17, 2025
AI Use Has Spiked In Tax Agencies Globally, OECD Says
The use of artificial intelligence has skyrocketed in tax administrations around the world, leading to increased efficiency but also increased risks of data quality issues, according to an Organization for Economic Cooperation and Development report released Monday.
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November 17, 2025
Belgium Postpones Global Minimum Tax Filing Deadline
Belgium will extend the deadline for multinational companies to file their returns as part of the 15% global minimum corporate tax regime until June 2026, the finance ministry announced Monday.
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November 14, 2025
DC Circ. Mulls Reviving Guinea $21M Award Suit
A D.C. Circuit panel on Friday appeared open to reviving a Seychelles company's bid to enforce an arbitral award of more than $21 million against the Republic of Guinea, focusing oral arguments on whether the country "made" the underlying arbitration agreement even if it wasn't a party to it.
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November 14, 2025
IRS Expert Challenges Data Used In Eaton's Projections
An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.
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November 14, 2025
Perkins Coie Sued By Omani Co. Over Trade Case Defense
An Omani screw manufacturer has launched a legal malpractice suit in Washington state court accusing Perkins Coie LLP of a "series of deadly mistakes" while representing the Middle Eastern company in a U.S. Department of Commerce probe, allegedly leading to steep penalties and tariffs that cost the company hundreds of millions of dollars.
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November 14, 2025
Estonia Wants Optional Minimum Tax For Small EU Countries
The global minimum tax's international provisions should be made optional permanently for smaller European Union countries, considering the U.S. may be exempted from them, Estonia's Finance Ministry said.
Expert Analysis
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.
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Legal Jeopardy Looms Over Trump's Trade Negotiation Plans
Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.
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What US-India Trade Deal Will Mean For Indian Pharma
Complicated by newly imposed tariffs from the U.S., the outcome of the U.S.-India trade talks is poised to reshape not just trade policy, but also the strategic alignment of the two countries' pharmaceutical ecosystems, says Jashaswi Ghosh at Holon Law Partners.
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Bar Exam Reform Must Expand Beyond A Single Updated Test
Recently released information about the National Conference of Bar Examiners’ new NextGen Uniform Bar Exam highlights why a single test is not ideal for measuring newly licensed lawyers’ competency, demonstrating the need for collaborative development, implementation and reform processes, says Gregory Bordelon at Suffolk University.
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A Simple Way Courts Can Help Attys Avoid AI Hallucinations
As attorneys increasingly rely on generative artificial intelligence for legal research, courts should consider expanding online quality control programs to flag potential hallucinations — permitting counsel to correct mistakes and sparing judges the burden of imposing sanctions, say attorneys at Lankler Siffert & Wohl and Connors.
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The Legal Education Status Quo Is No Longer Tenable
As underscored by the fallout from California’s February bar exam, legal education and licensure are tethered to outdated systems, and the industry must implement several key reforms to remain relevant and responsive to 21st century legal needs, says Matthew Nehmer at The Colleges of Law.
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6 Questions We Should Ask About The Trump Trade Deals
Whenever the text becomes available, certain questions will help determine whether the Trump administration’s trade deals with U.S. trading partners have been crafted to form durable economic relationships, or ephemeral ties likely to break upon interpretive disagreement or a change in political will, says Ted Posner at Baker Botts.
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E-Discovery Quarterly: Rulings On Relevance Redactions
In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.