International
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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.
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April 30, 2025
Ex-Treasury Official Joins Baker McKenzie's Tax Practice
Baker McKenzie has hired a former deputy assistant secretary at the Treasury Department to work on international tax matters as a partner in the firm's office in Washington, D.C.
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April 30, 2025
HMRC Should Use AI To Boost Services, Report Says
HM Revenue & Customs is still not doing enough to improve its services and should prepare to use artificial intelligence to enhance customer service for U.K. taxpayers and increase its productivity, according to a parliamentary report.
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April 29, 2025
Immigration Ruling No Help To Liberty Global, 10th Circ. Told
Liberty Global cannot use a U.S. Supreme Court ruling on interpreting ambiguous law in an immigration case to support the company's interpretation of law in its $248 million foreign tax credit claim, the federal government told the Tenth Circuit.
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April 29, 2025
Bessent Says EU Must Kill Digital Taxes For US Trade Deal
The U.S. government wants European countries to repeal digital service taxes before the European Union moves forward with trade negotiations, U.S. Treasury Secretary Scott Bessent said Tuesday.
Expert Analysis
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.