International
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March 11, 2025
Retailer Fights US On Overriding Jury In $11.6M FBAR Case
A federal jury in Hawaii was justified in finding that an international businessman hadn't willfully failed to report his foreign bank accounts in an $11.6 million dispute, and the U.S. government is not entitled to an overruled verdict or new trial, he told the court.
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March 11, 2025
Russia Says Guinea Ruling Backs Dismissal In $5B Award Suit
A recent D.C. federal court decision supports the Russian Federation's bid to dismiss an arbitration enforcement action stemming from a tax dispute with Yukos Capital Ltd., Russia told the same court.
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March 11, 2025
12 Govs. Assert States' Sovereignty Against CTA In 5th Circ.
A dozen Republican governors, led by Georgia Gov. Brian Kemp, urged the Fifth Circuit to maintain a nationwide block of enforcement of the Corporate Transparency Act, arguing the law undermines the traditional authority states have to regulate businesses.
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March 11, 2025
Carlton Fields Tax Ace Jumps To Trenam Law In Fla.
Florida's Trenam Law has added a past chair of the tax section of the state bar after her 25-year stint at Carlton Fields PA.
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March 11, 2025
EU Council Approves 'Decluttering' Tax Agenda
The Council of the European Union said Tuesday that it has approved the "decluttering" agenda to simplify tax legislation across the bloc and cut red tape to make the system more competitive.
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March 11, 2025
EU Council Agrees On Reporting Rules To Back Min. Corp. Tax
The Council of the European Union said Tuesday it has reached an agreement to enact reporting rules to support the 15% global minimum corporate tax rate across the EU.
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March 11, 2025
EU Council Adopts Digital VAT Reform Package
The Council of the European Union said Tuesday that it has adopted reforms to adapt the EU's value-added tax regime to the digital economy.
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March 10, 2025
Tariff Shifts Creating Compliance Chaos For Energy Cos.
The unpredictability of President Donald Trump's tariff maneuvers is challenging energy companies' ability to comply with fluctuating mandates and making tariff violations more likely.
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March 10, 2025
EU Tax Revenue Hits €6.7T, Lowest GDP Share Since 2011
While European Union members' collective tax revenue was up nearly 5% to more than €6.7 trillion ($7.3 trillion) in 2023, tax revenue as a share of gross domestic product in the bloc was the lowest it has been since 2011 thanks to inflation, a news release said Monday.
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March 10, 2025
Ex-Credit Suisse Client Pleads Guilty To Hiding $90M
A Colombian-American businesswoman and former Credit Suisse client pled guilty Monday in Florida federal court to conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.
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March 10, 2025
Feds Sue FDIC For $1.9M For First Republic Tax Bill
The U.S. government sued the Federal Deposit Insurance Corp. in D.C. federal court as receiver for the failed First Republic Bank, alleging the bank understated its withholding tax for U.S.-sourced income of foreigners and now owes almost $2 million to the federal government.
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March 10, 2025
Treasury's CTA Halt Doesn't Justify Block, Feds Tell 5th Circ.
The U.S. Treasury Department halting enforcement of the Corporate Transparency Act on domestic entities doesn't add justification to a nationwide block on the law because it's a valid exercise of Congress' powers to regulate commerce, taxes, foreign affairs and national security, the U.S. government told the Fifth Circuit.
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March 10, 2025
Court Affirms FBAR Penalties Against Estate, Not Widow
The estate of a man who failed to report his Swiss bank accounts is liable for tax penalties of at least $2 million, an Idaho federal court determined, finding the man's widow off the hook.
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March 10, 2025
Tax Pro Rejoins Norton Rose From Reed Smith In Houston
Norton Rose Fulbright announced Monday that it has bulked up in the face of increased demand in the corporate transactions space with the return of a tax partner in Houston who came aboard from Reed Smith LLP.
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March 10, 2025
Int'l Tax Changes Can Help Gender Equality, Economists Say
Countries could address persistent gender gaps in tax systems by overhauling their approach for wealthy individuals and multinational corporations, according to a group of economists, who said low female shares of capital income and wealth currently limit related tax benefits.
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March 10, 2025
German Election Raises Doubts About Pillar 2 From Tax Pros
The new German government could end up abandoning the international corporate minimum tax agreement known as Pillar Two because of rising competition between the U.S. and Europe, experts told Law360.
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March 07, 2025
Mauritius Government Lawyer Joins CMS Affiliate
CMS said an attorney with more than a decade of experience as a Mauritius government lawyer has joined CMS Prism, the firm's Mauritian affiliate.
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March 07, 2025
NFTC Supports Broader, Elective Adoption Of Amount B
The U.S.' proposed adoption of the OECD's approach to pricing certain cross-border transactions, known as Amount B, should go beyond just marketing and distribution activities, the National Foreign Trade Council said Friday, suggesting it be extended to services and other baseline activities.
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March 07, 2025
Calif. Man Must Pay $230K In FBAR Penalties After Default
A federal court ordered a Californian accused of withholding reports of his Swiss bank accounts from the Internal Revenue Service to pay more than $230,000 after awarding the U.S. government a default judgment.
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March 07, 2025
Peru Broke Trade Deal, Scotiabank Tells Arbitrators
Scotiabank asked the World Bank's international arbitration institution to consider a new argument in a value-added tax dispute with the Peruvian government, saying Peru's treatment of the bank violated a trade agreement with Canada.
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March 07, 2025
Taxation With Representation: Kirkland, Wachtell, Skadden
In this week's Taxation With Representation, Walgreens Boots Alliance goes private via a deal with Sycamore Partners, Honeywell buys Sundyne from Warburg Pincus, and Jazz Pharmaceuticals acquires Chimerix.
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March 07, 2025
Four Men Imprisoned For 43 Yrs For Money Laundering Plot
Four men involved in a plot to launder £266 million ($343 million) in criminal cash were on Friday sentenced to a total of more than 43 years in prison, in one of the biggest cases of its kind ever prosecuted in England.
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March 07, 2025
2 Arrested In €64M VAT Fraud Involving VoIP In Italy
Italian authorities arrested two people in connection with a €64 million ($69 million) value-added tax fraud scheme involving services that let users make phone calls via the internet, the European Public Prosecutor's Office said Friday.
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March 07, 2025
Switzerland Opens FATCA Consultation
The Swiss government is holding a consultation on the details of a new, reciprocal agreement for exchanging financial data with the U.S. under the Foreign Account Tax Compliance Act, according to a statement Friday.
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March 06, 2025
€130B In Added Revenue ID'd By OECD Info Exchanges
International implementation of the Organization for Economic Cooperation and Development's exchange of information programs identified €130 billion ($140 billion) in additional tax revenue from 2009 through 2023, with roughly a third of that added revenue — €45 billion — identified by developing nations, the OECD said Thursday.
Expert Analysis
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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7 Common Myths About Lateral Partner Moves
As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.