International
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May 02, 2025
US, China Battling Over Entrenched Economies, Experts Say
Differing economic philosophies are contributing to the escalating trade war between the United States and China, according to professionals who follow the countries' relations, with the Chinese government's supply-side ideology rooted in exports and U.S. deficit spending driving demand for imports.
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May 02, 2025
Money Laundering, Tax Charges Nixed Vs. Crypto Operator
An Indiana federal judge dismissed the U.S. government's cases against a man accused of operating an unlicensed money transmitting business, laundering proceeds through cryptocurrency transactions and failing to file tax returns after finding his business was not subject to registration requirements, as the government had maintained.
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May 02, 2025
Glencore Exec Can't Duck Tax On £150M In Offshore Shares
Glencore's former head of oil failed to overturn a finding he was liable for income tax on nearly £150 million ($200 million) in share distributions from the Jersey-incorporated company, when an appeals court concluded Friday it was subject to U.K. taxation.
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May 02, 2025
IRS Updates Rates For Foreign Insurance Company Equations
The Internal Revenue Service on Friday published updated domestic asset/liability and yields percentages for 2024 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.
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May 02, 2025
Taxation With Representation: Goodwin, Haynes Boone
In this week's Taxation With Representation, Merck buys SpringWorks Therapeutics, Novartis AG acquires Regulus Therapeutics Inc., Sabre Corp. sells its Hospitality Solutions business to private equity shop TPG, and TWG Global and Mubadala Capital team up to bolster their investments.
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May 02, 2025
Community Groups Accept Pause In CTA Litigation
A group of community associations has told the Fourth Circuit they aren't opposed to a government motion to pause litigation over the Corporate Transparency Act, even as they maintained the information disclosure law aimed at small businesses still carries constitutional flaws.
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May 01, 2025
Irish Tax Appeals Board Closed €355M In Cases In 2024
Ireland's Tax Appeals Commission closed more than 1,711 appeals cases in 2024, a 12% increase over the year prior and valued at €355 million ($401 million) in taxes, the commission said in a report.
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May 01, 2025
Multinationals Grapple With Tariff-Induced Pricing Issues
President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.
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May 01, 2025
Trump Picks Tax Controversy Pro For IRS Chief Counsel Spot
President Donald Trump has tapped a former Internal Revenue Service chief counsel to return to the role, and if he is confirmed, it will represent the second time in his career that the veteran tax controversy professional will be the agency's top attorney.
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May 01, 2025
Chilean Digital Platforms Must Show Users' Tax Compliance
Digital platforms operating in Chile will need to show that those either contracting their services or using them to offer their owns goods and services are tax-compliant starting in 2026, Chile's tax administration said.
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May 01, 2025
Canada Looks To Guide Exporters Navigating US Tariffs
The Canadian government is offering new resources for exporters dealing with what it called unjustified U.S. tariffs, providing information on rules of origin and customs procedures under the U.S.-Canada-Mexico Agreement.
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May 01, 2025
Estate Pushes Back On IRS In DC Circ. Lost Records Case
The estate of a man whose offshore businesses were raided by the IRS, giving rise to a nearly $18 million tax judgment, criticized the agency's effort to rebuff the estate's claims to the D.C. Circuit that the IRS fraudulently claimed that boxes of evidence in ensuing litigation were lost.
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May 01, 2025
Ore. Tax Court Retains Nix Of Microsoft Foreign Income Relief
The Oregon Tax Court is adhering to its finding on the treatment of Microsoft's repatriated foreign income when calculating its state income, making only minor changes to an earlier order and rejecting the company's arguments for further relief.
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May 01, 2025
ECB Says Consumers Ready To Avoid US Goods Over Tariffs
European consumers are prepared to avoid American goods for the long term, following the impact of tariffs imposed by the U.S. administration, according to a survey by the European Central Bank.
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May 01, 2025
BNY Can't Escape A&O Shearman's £93M Negligence Claim
Bank of New York Mellon lost its fight Thursday to escape a claim from Allen Overy Shearman Sterling alleging that the lender caused Nationwide Building Society to face a £93 million ($109 million) tax bill by bungling the issuance of notes.
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April 30, 2025
Senate Rejects Bill To End Trump's Nat'l Emergency On Tariffs
The U.S. Senate narrowly rejected a bipartisan bill Wednesday that sought to end the national emergency declared by President Donald Trump to underpin his global tariff regime, with two senators absent for the vote, and with U.S. House consideration delayed until October.
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April 30, 2025
Workers' Effective Tax Rates In OECD Up Again, But So Is Pay
While the effective tax rates on labor across the Organization for Economic Cooperation and Development's 38 member countries on average ticked up for a third year in a row in 2024, average wages were up in all but four countries after dropping over the prior two years, the OECD said Wednesday.
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April 30, 2025
US Economy Shrank 0.3% In First Quarter As Imports Surged
U.S. gross domestic product fell at an annual rate of 0.3% in the first quarter of 2025 as importers stockpiled goods in advance of President Donald Trump's global tariff regime, the U.S. Department of Commerce announced Tuesday.
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April 30, 2025
EU Busts $10M VAT Fraud Ring Involving Chinese Imports
The European Anti-Fraud Office and Polish authorities uncovered a value-added tax fraud ring that exploited European Union rules to dodge over 38.2 million Polish zloty ($10.1 million) in value-added taxes on goods imported from China, they said Wednesday.
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April 30, 2025
Morgan Lewis Expands Tax Practice With Milbank Hire
Morgan Lewis & Bockius LLP added a former Milbank special counsel as a tax partner based in the firm's London office.
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April 30, 2025
Dentist Fights HMRC Over Alleged Tax Avoidance
A dentist's firm urged an appeals court on Wednesday to find that it had not engaged in tax avoidance by making loan payments to its owner through a trust, saying the payments had no connection to its owner's employment and therefore were not taxable as income.
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April 30, 2025
Switzerland Begins Consultation On Pillar 2 Return Rules
The Swiss government said Wednesday that it has begun the consultation process to create compliance rules for a global information return that companies must submit as part of an international minimum corporate tax agreement known as Pillar Two.
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April 30, 2025
Sheppard Mullin Brings On Kirkland Tax Ace In Houston
Sheppard Mullin Richter & Hampton LLP announced Wednesday that it expanded its tax, employee benefits and trusts and estates practice with a new partner most recently with Kirkland & Ellis LLP.
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April 30, 2025
Dem Reps. Urge Court To Block IRS-ICE Info-Sharing Pact
House Democrats and two organizations that help immigrants prepare tax returns urged a D.C. federal court to block the Internal Revenue Service from sharing with immigration enforcement agencies the names and addresses of people suspected of being in the country illegally.
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April 30, 2025
Fried Frank Taps Sidley's UK Tax Head
The former head of Sidley Austin LLP's U.K. tax practice has joined Fried Frank Harris Shriver & Jacobson LLP's London office, where he will advise on U.K. and international tax structuring, the firm announced.
Expert Analysis
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.
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What's Next For Russia Sanctions After Task Force Disbanded
Attorney General Pam Bondi’s recent disbanding of Task Force KleptoCapture, which was initially aimed at seizing Russian oligarchs’ funds and assets, is unlikely to mean the end of Russia sanctions enforcement and other economic countermeasures, as the architecture for criminal enforcement remains in place, say attorneys at BakerHostetler.
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How Law Firms Can Counteract The Loneliness Epidemic
The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.
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5 Keys To Building Stronger Attorney-Client Relationships
Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.
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Attorneys Must Act Now To Protect Judicial Independence
Given the Trump administration's recent moves threatening the independence of the judiciary, including efforts to impeach judges who ruled against executive actions, lawyers must protect the rule of law and resist attempts to dilute the judicial branch’s authority, says attorney Bhavleen Sabharwal.
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Rethinking 'No Comment' For Clients Facing Public Crises
“No comment” is no longer a cost-free or even a viable public communications strategy for companies in crisis, and counsel must tailor their guidance based on a variety of competing factors to help clients emerge successfully, says Robert Bowers at Moore & Van Allen.
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Reading The Tea Leaves On Mexico, Canada And China Tariffs
It's still unclear whether the delay in the imposition of U.S. tariffs on Canadian and Mexican imports will result in negotiated resolutions or a full-on trade war, but the outcome may hinge on continuing negotiations and the Trump administration's possible plans for tariff revenues, say attorneys at Eversheds Sutherland.
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How Design Thinking Can Help Lawyers Find Purpose In Work
Lawyers everywhere are feeling overwhelmed amid mass government layoffs, increasing political instability and a justice system stretched to its limits — but a design-thinking framework can help attorneys navigate this uncertainty and find meaning in their work, say law professors at the University of Michigan.
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The Pros And Cons Of A 2nd Trump Term For UK Tech Sector
While U.S. President Donald Trump’s protectionist stance on trade could disrupt global supply chains on which many U.K. tech firms are reliant, anticipated deregulation could provide fertile ground for investment and growth, and the U.K. tech sector is bracing for a mix of opportunities, say lawyers at Shoosmiths.
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Corp. Transparency Act's Future Under Treasury's Bessent
The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.
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A Look At A Possible Corporate Transparency Act Exemption
Attorneys at Kirkland offer a deep dive into the application of the Corporate Transparency Act's reporting requirements specifically to U.S.-domiciled co-issuers in typical collateralized loan obligation transactions, and consider whether such issuers may be able to assert an exemption from the CTA's reporting requirements.
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Inconsistent Injury-In-Fact Rules Hinder Federal Practice
A recent Third Circuit decision, contradicting a previous ruling about whether consumers of contaminated products have suffered an injury in fact, illustrates the deep confusion this U.S. Supreme Court standard creates among federal judges and practitioners, who deserve a simpler method of determining which cases have federal standing, says Eric Dwoskin at Dwoskin Wasdin.
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In-House Counsel Pointers For Preserving Atty-Client Privilege
Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.