International
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October 31, 2025
Up Next At High Court: Tariffs, Fugitives & Contractor Liability
The U.S. Supreme Court will begin its November oral argument session Monday, during which the justices will consider President Donald Trump's authority to impose tariffs on foreign countries under an emergency statute, whether military contractors can be held liable for alleged breaches of contracts in war zones, and if there are time limits for litigants who want to vacate a void judgment. Here, Law360 breaks down the week's oral arguments.
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October 31, 2025
OECD Reports Rise In Failed Advance Pricing Agreements
The number of advance pricing agreements that were rejected or closed without an accord rose 19% last year compared with the previous year, and slightly fewer agreements were granted overall, the Organization for Economic Cooperation and Developmen said Friday.
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October 31, 2025
UK Co. Can't Shake £8.4M Tax On Goods Imported For Repair
A U.K. subsidiary of a U.S. industrial equipment company isn't entitled to recover roughly £8.4 million ($11 million) in value-added tax on goods it brought into the U.K. for repair and servicing, a London tribunal ruled.
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October 31, 2025
OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases
Tax authorities began more than 2,500 mutual agreement procedure cases last year involving transfer pricing, a record number representing a 29% increase from the previous year, the Organization for Economic Cooperation and Development said Friday.
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October 31, 2025
Taxation With Representation: Skadden, Davis Polk
In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.
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October 31, 2025
Australia Issues Guidance On Public Country-By-Country Law
Australia issued guidance Friday on how to comply with its public country-by-country reporting law, including filing instructions, formatting and the information required to be disclosed.
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October 31, 2025
5 Indicted In Germany In €188M VAT Fraud Scheme
Five German residents have been indicted on charges related to their participation in a €188 million ($217 million) value-added tax fraud scheme, European Union authorities said Friday.
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October 30, 2025
Trade Deals At Risk In Trump Tariff Case, Feds Tell Justices
The federal government told the U.S. Supreme Court on Thursday that President Donald Trump's global tariffs have led to significant trade deals addressing the underlying national emergencies he declared, and a ruling determining them unlawful would prove catastrophic.
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October 30, 2025
China Delays Expanded Mineral Export Controls, Trump Says
China has agreed to delay for a year an expansion to export controls for key minerals and is set to start purchasing more U.S. agricultural products including soybeans, while U.S. tariffs on Chinese goods will decrease 10%, President Donald Trump said early Thursday morning.
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October 30, 2025
Senate Votes To Ax Global Tariffs, But House Path Blocked
The Senate passed legislation Thursday to end the declared national emergency propping up President Donald Trump's global tariff regime shortly after passing similar bills regarding tariffs on Canada and Brazil, though the House previously moved its deadline for action on the matter to next year.
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October 30, 2025
IRS Discloses Record In ICE Data Sharing Case
The IRS, following a judge's order, has released its administrative record in a lawsuit over its agreement to share taxpayer information with federal immigration authorities, including emails in which officials discuss U.S. Immigration and Customs Enforcement's request for information on nearly 1.3 million taxpayers.
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October 30, 2025
French Legislators Vote To Double Digital Services Tax To 6%
Lawmakers in the lower house of France's Parliament voted to double the country's digital services tax rate from 3% to 6%, stopping short of an earlier proposal to increase the measure to 15% to mirror U.S. tariffs.
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October 30, 2025
Dutch Centrist Party Gains Seats With Tax Change Agenda
The centrist party Democrats 66 looks set to come out of the Dutch general election as the party best placed to lead the next government with an agenda to cut taxes for working people and raise rates on wealth and pollution, according to balloting counted Thursday.
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October 29, 2025
Senate Backs Axing Brazil Tariffs, But House Vote Blocked
The Senate voted to end a declared national emergency underpinning U.S. tariffs placed on Brazil for the prosecution of its former president over an attempted coup, but the House has delayed a statutory requirement to expedite accompanying legislation.
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October 29, 2025
Tribunal Walks Back HMRC's £1M Share Sale Decision
HM Revenue & Customs incorrectly increased a man's income tax liability by over £1 million ($1.3 million) on the sale of shares in a company as part of his retirement plan, a London tribunal ruled.
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October 29, 2025
IRS Wrongly Nixed Insurance Transactions, Tax Court Told
A Tennessee company that claims to provide in-house insurance to businesses supporting the U.S. Department of Defense and NATO has challenged more than $500,000 in tax liabilities and the IRS' denial of its status as an insurer, according to a U.S. Tax Court petition.
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October 29, 2025
Publix Heiress Asks To Quash IRS Summons For Bank Info
An heiress to the Publix grocery store chain asked a Florida federal court to quash an IRS summons seeking her bank information on behalf of Italian tax officials, arguing that the agency's request flouts the Italy-U.S. tax treaty.
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October 28, 2025
Baltimore Atty Found Personally Liable For Entity's Taxes
A Baltimore attorney who manages a client's holding company is personally responsible for paying the entity's unpaid taxes, a Maryland federal judge said, finding that he approved and oversaw loan transactions that prompted the IRS to seek $2 million from the entity.
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October 28, 2025
Shutdown Raises Concerns About IRS Reg Timing, 2026 Filing
The federal government shutdown is likely to delay critical IRS guidance for retroactive tax provisions in this summer's budget bill and impair customer service at the agency as it drags on, causing headaches for taxpayers, tax observers say.
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October 28, 2025
US, Japan Sign Agreement On Key Minerals
The U.S. and Japan agreed Tuesday to coordinate on securing and refining important minerals, while outlining a series of Japanese investments in U.S. industries, according to an announcement published by the White House.
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October 28, 2025
Norway Sees 30% Spike In Crypto Reporting To Tax Authority
Norway saw a 30% spike in taxpayers who reported owning cryptocurrency last year, the country's tax authority said Tuesday, attributing the increase to its compliance efforts.
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October 28, 2025
UN Committee Seeks Feedback On Tax Treaty, Dispute Ideas
Leaders of the intergovernmental negotiating committee on the United Nations framework convention on international tax cooperation are seeking comments on a template for the treaty and ideas for a protocol on dispute resolution.
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October 27, 2025
Cambodia Agrees To Cut Tariffs, Barriers In US Trade Deal
Cambodia agreed to cut tariffs, refrain from imposing a digital services tax, remove nontariff trade barriers and accept U.S. regulatory standards in a trade agreement with the U.S. in exchange for tariff exemptions.
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October 27, 2025
US Unveils Trade Frameworks For Vietnam, Thailand Deals
The U.S. issued new details on a framework trade deal it reached months ago with Vietnam and announced a new framework deal with Thailand, according to announcements made by the White House on Sunday.
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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.
Int'l Tax In October: Deal With China, Halt To Canada Talks
A tentative deal to reduce American tariffs on Chinese goods, ruptured trade talks between the U.S. and Canada, court defeats for the Danish and U.S. tax administrations and an end to the European Union's plan for a financial transaction tax topped the list of international tax news in October. Here, Law360 looks at the biggest developments from the past month.
EU's Top Court Axes Dutch Co.'s Challenge Against Pillar 2
The European Union's top court declined Thursday to revive a Dutch company's case against an EU directive that implements an international minimum tax agreement known as Pillar Two, holding that the business lacked standing to challenge the law.
Top UK Court Rules NHS Parking Services Subject To VAT
Britain's top court ruled Wednesday that provision of car parking services by a National Health Service trust should not be exempt from value-added tax, a decision that will affect dozens of stayed appeals by NHS entities worth up to £100 million ($132 million).
Featured Stories
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French Digital Tax Ruling Puts Spotlight On Trade Tensions
A French court decision that upheld the nation's digital services tax could bolster similar measures in other European Union member states, but legal backing may mean little if countries use DSTs as bargaining chips in tariff negotiations with the United States.
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Relief Concerns Grow As Sectoral Tariff Actions Build
Importers' hopes for relief from industrywide tariffs are lagging alongside the trade deals President Donald Trump is trying to broker for some goods, while the administration's accelerated rollout of sectoral levies is also stoking concerns the government may be hamstringing its onshoring goals.
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EU Digital VAT Plan May Put Smaller Rental Cos. In Tight Spot
The European Union's plan to make online platforms responsible for collecting value-added tax payable by their users could pose compliance challenges that threaten smaller short-term rental companies, experts say, while larger platforms such as Airbnb are more able to stomach the costs.
Expert Analysis
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Law School's Missed Lessons: Educating Your Community
Nearly two decades prosecuting scammers and elder fraud taught me that proactively educating the public about the risks they face and the rights they possess is essential to building trust within our communities, empowering otherwise vulnerable citizens and preventing wrongdoers from gaining a foothold, says Roger Handberg at GrayRobinson.
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5 Crisis Lawyering Skills For An Age Of Uncertainty
As attorneys increasingly face unprecedented and pervasive situations — from prosecutions of law enforcement officials to executive orders targeting law firms — they must develop several essential competencies of effective crisis lawyering, says Ray Brescia at Albany Law School.
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It's Time For The Judiciary To Fix Its Cybersecurity Problem
After recent reports that hackers have once again infiltrated federal courts’ electronic case management systems, the judiciary should strengthen its cybersecurity practices in line with executive branch standards, outlining clear roles and responsibilities for execution, says Ilona Cohen at HackerOne.
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Rules Of Origin Revamp May Be Next Big Trade Development
The rules of origin for determining what tariff applies to any given import appear to be on the cusp of an important rethink, and it seems likely that the administration will try to align the rule with its overall tariff strategy in one of three ways, says Ted Posner at Baker Botts.
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SDNY OpenAI Order Clarifies Preservation Standards For AI
The Southern District of New York’s recent order in the OpenAI copyright infringement litigation, denying discovery of The New York Times' artificial intelligence technology use, clarifies that traditional preservation benchmarks apply to AI content, relieving organizations from using a “keep everything” approach, says Philip Favro at Favro Law.
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High Court, Not A Single Justice, Should Decide On Recusal
As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
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Adapting To Private Practice: 3 Tips On Finding The Right Job
After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.
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Painting Makes Me A Better Lawyer
Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.
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Protecting Sensitive Court Filings After Recent Cyber Breach
In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.
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What Ethics Rules Say On Atty Discipline For Online Speech
Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.
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2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers
Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
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Junior Attys Must Beware Of 5 Common Legal Brief Mistakes
Excerpt from Practical Guidance
Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
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Power To The Paralegals: How And Why Training Must Evolve
Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.