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June 08, 2026
Barclays Loses VAT Appeal Over UK Fixed Establishment
A Barclays entity lacked a fixed establishment in the U.K. because its British branch was "skeletal" when the Delaware-based company applied for value-added tax grouping, a London tribunal ruled Monday.
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June 08, 2026
Liberty Global Seeks Rehearing In $2.4B Tax Substance Fight
Telecommunications firm Liberty Global wants another shot at showing the Tenth Circuit that it's entitled to a $2.4 billion deduction linked to transactions with foreign affiliates, claiming the court misapplied a rule that can disallow tax benefits from transactions that lack economic substance.
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June 08, 2026
Energy Transactions Atty Returns To McGuireWoods In SF
A senior vice president with Aon's global mergers and acquisitions and transactions solutions team has rejoined McGuireWoods LLP as a partner in San Francisco, the firm announced Monday.
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June 08, 2026
Developers Stumped By Energy Credits' Foreign Debt Limits
Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.
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June 08, 2026
McKesson Can't Defeat Valid Cost-Sharing Rules, Gov't Says
The U.S. government urged a Texas federal court to uphold transfer pricing regulations that pharmaceutical giant McKesson is challenging in its push for a nearly $10 million tax refund, arguing the rules fall "well within the bounds" of the underlying statutory text.
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June 06, 2026
Inheritance Tax Penalties Surge By 35%, Data Shows
Britain's tax authority imposed 35% more penalties for late inheritance tax returns in tax year 2024-25 compared with 2020-21, according to government data released by a law firm Saturday.
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June 05, 2026
Calif.'s Global Reporting Bill Could Embolden Other States
A California bill that would require multinational corporations to report their global profits could spark similar legislation across the U.S. if lawmakers of revenue-hungry states perceive shortcomings in federal and international efforts to tackle profit shifting.
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June 05, 2026
11th Circ. Lets Man Fight $2.2M FBAR Penalties As Excessive
A Georgia federal court correctly found that the owner of a sports equipment business willfully failed to disclose his foreign bank accounts, but it must give him a chance to challenge $2.2 million in resulting penalties as excessive under the Eighth Amendment, the Eleventh Circuit said.
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June 05, 2026
Abbott Says Timing Mismatch Lets $8B Gain Go Untaxed
Abbott Laboratories asked the U.S. Tax Court to find that it needn't recognize an $8 billion gain in 2020 from transactions between several of its controlled foreign corporations because of a mismatch in the effective dates of different sections of the 2017 U.S. Tax Cuts and Jobs Act.
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June 05, 2026
HMRC's Reading Would Double-Tax £10M, Upper Tribunal Told
Shareholders of a holding company argued before the Upper Tribunal on Friday that HM Revenue & Customs misinterpreted tax legislation, risking the same £10 million ($13.4 million) in payouts being taxed twice after a capital reduction.
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June 05, 2026
Taxation With Representation: Simpson Thacher, Fried Frank
In this week's Taxation With Representation, Berkshire Hathaway Inc. takes Taylor Morrison Home Corp. private, global real estate investment company Kennedy Wilson forms a residential joint venture with Netherlands pension services provider APG, and Wellington Management acquires Hartford Funds from insurer The Hartford.
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June 05, 2026
Wife Of Bankrupt Former EY Tax Chief Sued By Trustees
The bankruptcy trustees of former EY head of tax John Dixon are bringing a claim against his wife, according to a newly public entry on the High Court's filing system.
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June 05, 2026
Irish Presidency Outlines Forecast For EU Tax Info Shake-Up
The incoming Irish presidency of the Council of the European Union outlined predictions for EU tax changes — including some related to information sharing — in a note to policy experts seen by Law360 on Friday.
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June 04, 2026
Feds Appeal Trade Court's Emergency Tariff Refund Order
The federal government has appealed the U.S. Court of International Trade's order requiring refunds on all duties paid under the International Emergency Economic Powers Act after the U.S. Supreme Court struck them down this year, according to filings in the trade court and Federal Circuit.
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June 04, 2026
HMRC Defends Tax Win In £10M Share Payout Dispute
The U.K.'s tax authority told a London court Thursday that a shareholder payout falls within anti-tax avoidance rules in a case concerning the tax treatment of £10 million ($13.4 million) in shares paid out following a capital reduction.
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June 04, 2026
Ex-Surgeon Agrees To $7.7M Tax Bill From Offshore Scheme
A retired plastic surgeon reached a $7.7 million settlement with the federal government to resolve an Internal Revenue Service case alleging that he ran an offshore employee leasing scheme, according to an agreement filed in an Ohio federal court.
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June 04, 2026
EU Tobacco Tax Bill Dropped From Upcoming Negotiations
Ambassadors from European Union countries failed to reach an agreement on a controversial EU tobacco taxation bill, according to an EU official, meaning the file has been withdrawn from the agenda of an upcoming meeting of member state finance ministers.
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June 04, 2026
EU Calls On Germany, Poland, Spain To Correct Tax Policies
The European Union's executive branch has called on Germany, Poland and Spain to end tax policies that it has determined violate the bloc's rules.
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June 04, 2026
OECD Urges Nations to Mull Tax Breaks In Pillar 2 Safe Harbor
Countries should "think carefully" about how their tax incentives will fit into a side-by-side safe harbor under the 15% global minimum corporate tax known as Pillar Two, the Organization for Economic Cooperation and Development said in a report released Thursday.
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June 04, 2026
HMRC Arrests Two Over Suspected £153M TikTok Tax Scam
The tax authority said Thursday that it had arrested two men suspected of using TikTok to perpetrate an alleged multi-million-pound tax fraud by persuading users to hand over tax account details with the promise of "quick cash."
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June 03, 2026
Texas Instruments Defends Deductions For Exercised Options
Texas Instruments challenged total deficiencies of $47.9 million for 2018 and 2019, much of it from the IRS' disallowance of deductions for deferred compensation, such as exercised stock options, under an approach consistent with a 2022 agency advice memorandum.
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June 03, 2026
UK Adults Unaware Of Inheritance Tax Relief, Insurer Says
Almost three-quarters of British adults don't know that certain gifts are exempt from inheritance tax as the fiscal rules for estates and pensions are set to change in April 2027, according to research published Wednesday.
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June 03, 2026
USTR Floats Double-Digit Tariffs On Basis Of Forced Labor
Sixty economies are facing added tariffs of either 10% or 12.5% on their exports to the U.S. following investigations by the U.S. Trade Representative's Office into countries' protections against the importing of goods produced with forced labor.
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June 03, 2026
Iran War Driving Slower Growth, Surging Inflation, OECD Says
The Iran war is driving slower growth and surging inflation across the global economy, and U.S. tariff policy is adding to uncertainty, the OECD said Wednesday during a virtual news conference.
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June 03, 2026
USTR Seeks Input On China Preferential Trade Mechanism
The Office of the U.S. Trade Representative announced what it is calling a government-to-government mechanism that will manage bilateral trade between the U.S. and China, including by considering tariff cuts, and asked for public comments on the program's development.
Expert Analysis
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US Reassessment Of OECD Tax Deal Is Right Move
The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.
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Measuring And Mitigating Harm From Discriminatory Taxes
In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.
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Adapting To Private Practice: From DOJ Leadership To BigLaw
The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.
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How The CRE Industry Is Adapting To Tariff Uncertainty
Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.
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Law Firm Executive Orders Create A Legal Ethics Minefield
Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.
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Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike
The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.
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Firms Must Embrace Alternative Billing Models Or Fall Behind
As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.
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How Attorneys Can Master The Art Of On-Camera Presence
As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.