International
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October 27, 2025
Malaysia Agrees To Toss Digital Tax In Trade Pact With US
Malaysia agreed to stop imposing its digital services tax on U.S. companies, invest $70 billion stateside and lower trade barriers on American goods in a trade agreement with the U.S. in exchange for tariff exemptions.
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October 27, 2025
Australia Considering Updates To OECD Global Min. Tax
Amendments clarifying rules on securitization entities are among updates proposed by the Australian Treasury for the country's legislation that implements the Pillar Two international minimum corporate tax agreement.
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October 27, 2025
Welsh Body Settles HMRC Contractor Tax Probe For £14.6M
An environmental body sponsored by the Welsh government reached a settlement of £14.6 million ($19.5 million) with the U.K. tax authority over its past use of contractors and misclassification of them for tax purposes, according to a statement.
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October 27, 2025
Accounting Firm Denies Liability For Investor's £633K Tax Bill
An accountancy firm has denied an investor's accusations that it was negligent in giving tax planning advice that resulted in him being hit with a £633,000 ($844,217) liability assessment, saying he had failed to distinguish between two tax schemes.
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October 27, 2025
Director Misused Confidential Info To Market Tax Scheme
A London court has ruled that the director of a tax-efficient investment product company misused confidential information by taking features of an accountant's money-saving tax structure to market in breach of a nondisclosure agreement.
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October 24, 2025
Former Judges Tell Justices To Strike Down Trump's Tariffs
Former federal judges and government officials, joined by scholars, economists, businesses and interest groups, told the U.S. Supreme Court this week that President Donald Trump's emergency tariffs should be struck down because the law the president has utilized does not give him power to impose those measures.
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October 24, 2025
Tax Pros Expect No IRS Word Soon On 'Friendly Doctor' Deals
The tax treatment of private equity investments in medical firms and other professional practices remains unresolved as the Internal Revenue Service delays updates to long-awaited consolidated return regulations and focuses instead on implementing the new 2025 Republican budget law, tax experts said Friday.
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October 24, 2025
USTR To Probe China's Adherence To 2020 Trade Deal
The Office of the U.S. Trade Representative opened an investigation Friday into China's adherence to a 2020 trade deal after determining there has been an "apparent failure to comply" with its terms, an accusation disputed by a Chinese government representative who spoke with Law360.
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October 24, 2025
Trump Ends Canada Trade Talks Over Ontario's Reagan Ad
President Donald Trump said he ended trade negotiations with Canada because of an advertisement by Ontario's provincial government featuring critical remarks about tariffs by President Ronald Reagan.
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October 24, 2025
Taxation With Representation: Latham, Wachtell, Gibson Dunn
In this week's Taxation With Representation, Meta announces a joint venture with Blue Owl Capital to fund the development of a data center campus in Louisiana, private equity giants acquire medical technology company Hologic Inc., and National Fuel Gas Co. buys CenterPoint Energy Inc.'s Ohio natural gas utility business.
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October 24, 2025
Talks On Shipping Carbon Price Continue Despite Plan's Delay
The United Nations' maritime agency continued talks on the details of a global carbon price plan for shipping this past week despite the recent postponement of the plan amid U.S. opposition, experts taking part in the process said Friday.
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October 23, 2025
French Legislators Advance 15% DST To Mirror US Tariffs
France's digital services tax rate would rise from 3% to 15% under an amendment adopted by the lower house of Parliament's Finance Committee, which characterized the action as a "proportionate response" to tariffs imposed by the United States.
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October 23, 2025
US Oil Cos. Pay More Tax Abroad Than At Home, Report Says
American oil and gas companies with foreign extraction operations paid more than 80% of their total taxes abroad in recent years despite producing more oil and gas in the U.S. than everywhere else combined, a corporate transparency group said Thursday.
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October 23, 2025
IRS To Float Sourcing Rules For Certain Securities Loans
The Internal Revenue Service said Thursday it intends to propose regulations that would have it look to the borrower of certain securities, rather than the lender, when determining whether related payments are sourced from the United States.
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October 23, 2025
Law Firms Could Face £1.4B Bill Under Rumored Tax Change
Partners at law firms face paying up to £1.4 billion ($1.9 billion) more in tax each year if the government imposes a new tax on limited liability partnerships to help plug a hole in Britain's finances, UHY Hacker Young said Thursday.
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October 23, 2025
UK Court Denies Leisure Firm's Bid For Extra VAT Interest
A leisure services company can't claim additional interest of £8.2 million ($11 million) on value-added tax overpaid to HM Revenue & Customs because statutory interest provided full compensation, a British court ruled.
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October 23, 2025
Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion
Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.
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October 23, 2025
Ex-Clifford Chance Pro Hit With £8M Libel Claim By Barrister
A barrister has sued legal commentator Dan Neidle and his think tank for £8 million ($10.6 million), accusing the former Clifford Chance partner of engaging in a vendetta against him, according to court filings that have now been made public.
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October 22, 2025
Australia Issues Guidance For Minimum Tax Safe Harbor
Australia released guidance Wednesday detailing when companies can forgo detailed top-up tax calculations for a jurisdiction under a safe harbor for the 15% global minimum tax that is based on country-by-country reporting.
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October 22, 2025
US Among Few Places With Amount B Rules, OECD Reports
The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.
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October 22, 2025
'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says
Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.
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October 22, 2025
Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling
Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.
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October 22, 2025
Trade Court OKs $235K Tax Bill On Korean Soju Imports
South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.
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October 22, 2025
Canada Tax Agency Could Expand Audit Powers, Pro Says
Tax attorneys in Canada are closely watching a proposal that would give the country's revenue agency extensive audit powers, including the ability to take information under oath before any potential litigation begins, a practitioner said Wednesday.
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October 22, 2025
Switzerland Seeks Comments On Updated EU Tax Data Deal
The Swiss government is inviting public comments on an agreement it reached with the European Union to update the jurisdictions' agreement for the automatic exchange of tax information, it said Wednesday.
Expert Analysis
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5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.
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Evaluating The Current State Of Trump's Tariff Deals
As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.
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How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.
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Preserving Refunds As Tariffs Await Supreme Court Weigh-In
In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.
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Writing Musicals Makes Me A Better Lawyer
My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.
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Adapting To Private Practice: From Va. AUSA To Mid-Law
Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.
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7 Document Review Concepts New Attorneys Need To Know
For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.
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Agentic AI Puts A New Twist On Attorney Ethics Obligations
As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.
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Opportunity Zone's Future Corp. Tax Benefits Still Uncertain
Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.
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How GILTI Reform Affects M&A Golden Parachute Planning
Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.
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Demystifying The Civil Procedure Rules Amendment Process
Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.
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Parenting Skills That Can Help Lawyers Thrive Professionally
As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.
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Trump Tax Law's Most Impactful Energy Changes
The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.