International
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July 17, 2025
Canada Mulling Changes To Ability To Rewrite Transactions
Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.
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July 17, 2025
US Negotiating Global Min. Tax Carveout Accord, Official Says
The U.S. hasn't yet secured an agreement with other countries to exempt its companies from the international parts of the 15% global minimum tax despite reaching an "understanding" with the Group of 7 nations, but wider negotiations have begun, a U.S. Treasury Department official said Thursday.
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July 17, 2025
EU Warns Dutch Over Tax Breaks Favoring Foreign Investment
The Netherlands may have to face the Court of Justice of the European Union if it does not amend a tax measure that provides incentives for investment in foreign companies over domestic businesses, the European Commission announced Thursday.
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July 17, 2025
EU Lawmakers Push For Tax Data Hub To Combat Evasion
Members of the European Parliament approved proposals for tax changes across the European Union, including a tax data hub to streamline compliance across the bloc and help combat tax avoidance and evasion.
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July 17, 2025
US Challenge To Belgian Minimum Tax Rules Heads To ECJ
A Belgian court said Thursday it has asked the European Union's highest court to weigh in on a U.S. industry group's challenge to the country's global minimum tax rules.
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July 17, 2025
Tax Info Swaps Have Generated €135B Since 2009, OECD Says
The international push for widespread adoption of tax transparency measures such as exchanges of information has led to €135 billion ($156 billion) in added revenue — including taxes, penalties and interest — since 2009, the Organization for Economic Cooperation and Development said Thursday.
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July 17, 2025
Australia Seeks Comments On Pillar 2 Guidance
The Australian Taxation Office is looking for public comments on a pair of draft guidelines related to the country's adoption of the Organization for Economic Cooperation and Development's Pillar Two global corporate minimum tax on large multinational entities.
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July 16, 2025
OECD Mulling Tweaks To Arm's-Length Range Guidance
The Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday.
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July 16, 2025
Tax Losses Back Retired Prof's FBAR Penalties, US Says
A retired professor's admission in U.S. Tax Court that his failure to report his foreign bank accounts caused tax losses shows that a California federal court should affirm tax penalties against him of more than $400,000, the U.S. government said.
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July 16, 2025
EU Proposes New Tax On Large Cos. In Budget For 2028-2034
The European Commission raised the idea Wednesday of a new tax on all companies that operate in the European Union with more than €100 million ($116 million) in annual revenue to augment its €2 trillion budget proposal for 2028 through 2034.
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July 16, 2025
German Chancellor Calls For EU Halt To Global Minimum Tax
German Chancellor Friedrich Merz has called for the suspension of the European Union's rollout of the global corporate minimum tax, a German newspaper reported Wednesday.
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July 16, 2025
USTR To Probe Brazil's Trade Practices For Possible Tariffs
The Office of the U.S. Trade Representative announced Tuesday evening it will launch an investigation into Brazil's trade practices to determine whether tariff actions could be necessary after a request by President Donald Trump and prior tariff threats.
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July 16, 2025
India Uses AI In Fraudulent Tax Crackdown, Recovers $122M
A sweeping enforcement operation by the Indian tax authority used artificial intelligence and third-party financial data to uncover widespread abuse of tax deductions and exemptions, so far recovering 1,045 crore rupees ($122 million), the government said.
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July 16, 2025
Freight Co. Loses Interim Bid To Lift HMRC Export Controls
A warehouse operator and drinks merchant have lost a bid for interim relief against U.K. tax authority export controls imposed over tax fraud concerns, with a London court ruling they had an "uphill task" to prove the measures were unreasonable.
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July 15, 2025
Trump Says US Has Struck Trade Deal With Indonesia
President Donald Trump announced Tuesday that the U.S. has reached a trade deal with Indonesia that includes a 19% tariff on all goods exported by the Southeast Asian country to the U.S., while American goods exported there will be free of tariffs.
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July 15, 2025
Tax Return Preparer Cops To Role In $25M Fraud Scheme
A tax return preparer pled guilty in a California federal court for his role in a fraud scheme that involved submitting fake federal income tax returns to claim $25 million in refunds.
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July 15, 2025
UK Tech Co. Can't Deduct Tax Linked To VAT Fraud
HM Revenue & Customs was correct to deny a technology supplier's £1.3 million ($1.7 million) tax refund bid, a U.K. court ruled, holding that the company should have known that the underlying transactions were tied to value-added tax fraud.
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July 15, 2025
Insurers Keen On UK Captive Regime But Fear 'Gold-Plating'
The government has proposed new rules that it hopes will transform the U.K. into a global hub for captive insurance — but experts say that with formal regulation still to come they fear that "the devil will be in the detail."
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July 15, 2025
Ireland Spent €1.4B On R&D Tax Credits In 2023
Ireland's biggest tax expenditure by far is its research and development tax credit, with the country forgoing around €1.4 billion ($1.6 billion) in revenue in 2023 in connection to the credit, the Irish Department of Finance said Tuesday.
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July 15, 2025
PwC Settles Property Biz's £9M Tax Negligence Case
PwC has settled claims that it should pay £8.9 million ($12 million) for causing a property group to be penalized by the U.K. tax authority after the Big Four accountancy firm allegedly miscalculated its tax liabilities and incorrectly priced its properties.
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July 14, 2025
EU Law Doesn't Shield Eaton Records, US Tells 6th Circ.
The European Union's privacy law does not protect Eaton Corp. from having to disclose employee evaluation records in a transfer pricing dispute with the Internal Revenue Service, the U.S. government told the Sixth Circuit on Monday.
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July 14, 2025
GOP Lawmakers Back USTR Probe Into Foreign Drug Pricing
Republican members of Congress expressed support Monday for the Office of the U.S. Trade Representative's efforts against what the lawmakers referred to as anti-innovation policies abroad that, they said, require U.S. companies to take on the brunt of pharmaceutical research and development.
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July 14, 2025
Trump Threatens Tariffs On Russia Over Ukraine War
President Donald Trump said Monday that Russia must end its war with Ukraine within the next 50 days or else the U.S. will levy "severe tariffs" on Russian goods entering the U.S.
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July 14, 2025
CFTC Must Pay $3M In Atty Fees As Sanctions In Forex Case
A New Jersey federal judge ordered the U.S. Commodity Futures Trading Commission on Friday to pay back over $3.1 million in attorney fees to a foreign exchange company after dismissing the regulator's case for bad-faith sanctionable behavior.
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July 14, 2025
US Defends Seeking Man's Info From Apple In Swiss Tax Probe
The U.S. government urged a California federal court to enforce an IRS summons on Apple Inc. to produce records linked to the account of a dual Swiss-Italian citizen, arguing the summons is valid under the U.S.-Switzerland tax treaty.
Expert Analysis
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Top 3 Litigation Finance Deal-Killers, And How To Avoid Them
Like all transactions, litigation finance deals can sometimes collapse, but understanding the most common reasons for failure, including a lack of trust or a misunderstanding of deal terms, can help both parties avoid problems, say Rebecca Berrebi at Avenue 33 and Boris Ziser at Schulte Roth.
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A 2-Step System For Choosing A Digital Asset Reporting Path
Under the Internal Revenue Service's new digital asset reporting regulation, each type of asset may have three potential reporting destinations, so a detailed testing framework can help to determine the appropriate path, says Keval Sonecha at Sonecha & Amlani.
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
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E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.