International
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June 03, 2025
USTR Extends Exclusions From 2018 China Tariffs
The Office of the U.S. Trade Representative has extended tariff exclusions for certain products from China under a set of 2018 trade measures aimed at what the U.S. described as Beijing's restrictive intellectual property rules.
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June 03, 2025
Irish Court Says US Co.'s Irish Units Not Owed Treaty Benefits
Three Irish subsidiaries cannot benefit from the U.S.-Ireland tax treaty's provision of equally favorable treatment between U.S. and Irish residents because their ultimate parent entity, a Delaware financial firm, is disregarded for U.S. tax purposes, Ireland's Court of Appeal said in a judgment.
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June 03, 2025
Lawyer Given Suspended Sentence In Germany Over Cum-Ex
A business lawyer who was partly responsible for running a €428 million ($488 million) tax fraud scheme was issued a suspended sentence of almost two years, according to a verdict Tuesday in a Bonn court.
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June 03, 2025
The Law360 400: A Look At The Top 100 Firms
A rebound in client work sent the nation’s largest law firms into growth mode last year, driving a wave of hiring, mergers and strategic moves that reshaped the top tier of the Law360 400. Here's a preview of the 100 firms with the largest U.S. attorney headcounts.
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June 03, 2025
Ex-Pandora Boss To Blame For His Own Tax Bill, Adviser Says
A tax adviser has denied exposing the former president of jewelry giant Pandora, Peter Andersen, to significant liabilities tied to a €2.2 million ($2.5 million) French property deal, saying that any losses were caused by the ex-chief's deliberate and independent decisions.
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June 02, 2025
Montana Tribal Tariff Dispute Will Stay In US Trade Court
A Montana federal judge won't reconsider an order to transfer a challenge to President Donald Trump's Canada tariff orders by members of the Blackfeet Nation to the U.S. Court of International Trade, saying the CIT has historical jurisdiction over claims by tribal members on import and duty-related actions.
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June 02, 2025
White House Asks DC Circ. To Halt Tariff Injunction
The White House on Monday asked the D.C. Circuit to hit pause on a lower court ruling that found President Donald Trump's tariffs unlawful, arguing the "legally indefensible preliminary injunction" would impede sensitive trade negotiations if left unchecked.
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June 02, 2025
IRS Issues Interim Regs To Simplify Corp. AMT Determination
The Internal Revenue Service released temporary regulations Monday that offered a simplified method for large companies seeking to determine whether the 15% corporate alternative minimum tax applies to them, as well as penalty relief for those that underpaid the levy this year.
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June 02, 2025
Bahamas Looks To Update Corp. Minimum Tax Rules
The Bahamas is looking for input on changes to its adoption of the OECD's minimum corporate income tax on large multinationals in order to better align it with updated standards, among other goals, the country said.
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June 02, 2025
Finland Plans Further Tweaks To Soft Drink Tax After EU Input
While the European Commission broadly found that Finland's plan to alter its sugary drink tax to create different tiers based on sugar content didn't violate state aid rules, it called for some tweaks that the country will pursue, Finland's Finance Ministry said Monday.
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June 02, 2025
Halliburton Wants IRS To Release Docs In $35M Tax Dispute
The Internal Revenue Service should be ordered to comply with Halliburton's discovery requests in a dispute over a $35 million deduction for payments the company said it made to a foreign government to protect its employees from harassment, the company told a Texas federal court.
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June 02, 2025
GOP Budget Adds Punitive Twist To Talks On Digital Taxes
The House-passed budget's punitive tax hikes on companies and people from countries with digital services taxes is poised to complicate trade negotiations aimed at removing DSTs and to weaken foreign investment in the U.S., fiscal experts told Law360.
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June 02, 2025
Remote Workers Take German Tax Case To EU's Top Court
The European Court of Justice said Monday it will hear the case of two taxpayers against a German regional tax authority over whether Swiss residents working remotely are taxable in Germany.
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June 02, 2025
CJEU Set To Hear SocGen's Case In Swedish Tax Dispute
The Court of Justice of the European Union said Monday that it will hear the case of French banking giant Société Générale SA against the Swedish tax authority over the taxation of nonresident companies under the European treaty.
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June 02, 2025
OECD Releases Consolidated Text Of Data-Swap Guidance
The Organization for Economic Cooperation and Development published consolidated text of a global reporting standard Monday to help tax administrations exchange financial information about individuals who may be trying to hide money from their tax authorities at home.
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June 02, 2025
IRS To Hold Hearing On Sourcing Cloud Transaction Income
The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.
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May 30, 2025
US-China Trade Talks Could Resume After Stall Over Minerals
Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.
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May 30, 2025
Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight
An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.
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May 30, 2025
HMRC Correctly Handled Land Tax Dodge, UK Court Says
HM Revenue & Customs followed the correct procedures to collect taxes on six individuals who attempted to dodge the U.K.'s land tax by transacting with a special purpose vehicle in Guernsey, the Upper Tribunal ruled.
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May 30, 2025
Isle Of Man Agrees To Work With UK Against Tax Avoidance
Isle of Man authorities reached an agreement with the U.K. government to work together in a crackdown on promoters of tax avoidance schemes, according to a joint statement.
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May 30, 2025
UK Midsize Biz Owners Wary Of Risk Exposure, Report Says
Owners and operators of midsize U.K. businesses are just as wary of risk exposure in personal taxes as they are in business taxes except under certain circumstances, according to a report commissioned by HM Revenue & Customs.
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May 30, 2025
Taxation With Representation: Kirkland, Cravath, Latham
In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.
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May 29, 2025
DC Court Blocks Trump's Tariffs As Overreach Of Power
The International Emergency Economic Powers Act does not empower the president to impose tariffs, the D.C. federal district court said Thursday, ruling that President Donald Trump's global levies are unlawful and barring his administration from enforcing them on two toymakers who challenged the policies.
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May 29, 2025
Fed. Circ. Revives Trump Tariffs As It Weighs Appeal
The Federal Circuit temporarily reinstated President Donald Trump's global tariffs Thursday, a day after the U.S. Court of International Trade held that an emergency law did not give the president "unbounded authority" to impose the measures.
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May 29, 2025
Australia Outlines Compliance For Thin Capitalization Test
The Australian Taxation Office is looking for feedback on draft compliance guidance for corporations looking to use one of its new thin capitalization tests as they relate to cross-border financing arrangements, it said Thursday.
Expert Analysis
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Imagine The Possibilities Of Openly Autistic Lawyering
Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.
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Litigation Funding Disclosure Debate: Strategy Considerations
In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.
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5 Ways To Create Effective Mock Assignments For Associates
In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.
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Mentorship Resolutions For The New Year
Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.
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Tax Directive Marks Milestone In Harmonizing EU System
The Council of the European Union’s recently adopted tax directive is a significant step toward streamlining and modernizing procedures for member states, and will greatly reduce administrative burden and compliance costs for cross-border investors, says Martin Phelan at Simmons & Simmons.
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5 Litigation Funding Trends To Note In 2025
Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.
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Rethinking Litigation Risk And What It Really Means To Win
Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.
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Small Biz Caught In Corporate Transparency Act Crossfire
Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.
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No, Litigation Funders Are Not 'Fleeing' The District Of Del.
A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.
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5 E-Discovery Predictions For 2025 And Beyond
In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.
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What's Ahead As Transparency Act Comes To A Crossroads
Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.
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7 Ways 2nd Trump Administration May Affect Partner Hiring
President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.
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E-Discovery Quarterly: Rulings On Custodian Selection
Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.