International
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March 14, 2025
Judge Splits $79M Judgment In Danish Tax Fraud Case
A New York federal judge divided a nearly $79 million judgment against four investors and their pension plans after a jury in February found them liable for participating in a tax fraud scheme against the Danish government.
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March 14, 2025
Ex-Greenberg Traurig Atty Ordered To Pay $15.5M To IRS
A former Greenberg Traurig LLP attorney who was sentenced to prison for helping a musician skirt taxes owes $15.5 million in restitution to the Internal Revenue Service, a New York federal judge ruled.
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March 14, 2025
Taxation With Representation: Davis Polk, Paul Weiss
In this week's Taxation With Representation, Mallinckrodt PLC and Endo Inc. combine, Rocket Cos. buys Redfin, and Endo divests its international pharmaceuticals business to Knight Therapeutics Inc.
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March 14, 2025
Struck-Off Lawyer Can't Lift Ban After Misleading HMRC
A former consultant solicitor who misled HM Revenue and Customs to get a refund on stamp duty land tax has failed to have his professional ban lifted as a London court ruled on Friday that the sanction was fair and justified.
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March 13, 2025
Texan Calls $1.7M In FBAR Penalties Unconstitutional
Constitutional law bars the United States from imposing $1.7 million in penalties for failure to report foreign bank accounts, a Texan said in urging a federal court to dismiss such an assessment against her.
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March 13, 2025
Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told
The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.
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March 13, 2025
Australia Clarifying Managed Investment Trust Tax Regime
The Australian government is planning to update its income tax laws to make it clear that trusts ultimately owned by a foreign pension fund can use certain concessional withholding tax rates on eligible distributions to members, the country's assistant treasurer said Thursday.
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March 13, 2025
Belgian Firm Can Nix Dividends From Tax Base, Court Rules
A Belgian engineering company was entitled to reduce its tax base by excluding dividends from its subsidiaries in member states before taxation, as per EU law and contrary to Belgian law, the Court of Justice of the European Union said in a preliminary ruling Thursday.
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March 13, 2025
Former IRS Counsel Joins Hinshaw In Chicago
Hinshaw & Culbertson LLP announced that a longtime government attorney who most recently served as deputy managing counsel of the Internal Revenue Service Office of Chief Counsel in Chicago, has joined the firm's government practice as a partner.
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March 13, 2025
Akin's Energy Transition Group Grows With V&E Tax Atty
Akin Gump Strauss Hauer & Feld LLP has hired a Vinson & Elkins LLP tax counsel who has spent the past decade counseling clients on the federal income tax aspects of energy transition transactions, the firm announced Thursday.
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March 13, 2025
5th Circ. Asks If Enforcement Delay Affects CTA Challenge
The Fifth Circuit has asked for supplemental briefing in a challenge against the Corporate Transparency Act, asking whether the case is affected by the U.S. Treasury Department's recent decision to suspend enforcement of reporting rules for domestic companies.
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March 13, 2025
Trump's EU Threat May Aim To Boost Negotiation Leverage
President Donald Trump continued his trade tactics Thursday, threatening a 200% tariff on European alcohol imports that is almost certain to be another tool to leverage in future negotiations despite the economic uncertainty it creates.
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March 13, 2025
Funding Deficiency May Hinder UN Tax Talks, Group Says
Governments interested in pursuing a United Nations tax convention should step up funding for the organization, which is facing a budget shortfall, according to the Tax Justice Network, as U.S. arrears drag on quicker-than-usual funding from other countries.
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March 13, 2025
Insurance Brokers Could Get Tax Refunds After Court Ruling
U.K. insurance brokers could be in line for tax refunds from the state worth up to £400 million ($518 million) after a landmark court case, according to accountancy MHA.
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March 13, 2025
Wait To File Taxes If You Have Capital Gains, Canada Says
The Canada Revenue Agency recommended that taxpayers with capital gains wait to file their tax returns as it finalizes updates to its system to account for the delayed proposed increase in the inclusion rate, saying it will waive late-filing penalties.
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March 12, 2025
OECD Calls On Costa Rica To Limit Regressive Exemptions
Costa Rica's tax revenue makes up just 25% of the country's gross domestic product, thanks in part to regressive exemptions to value-added and personal income taxes and its overall narrow tax bases, the Organization for Economic Cooperation and Development said.
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March 12, 2025
Judge Tosses Tax Fraud Claim In Mariana Bribery Case
A federal court dismissed Wednesday a claim connected to allegations of tax fraud in a $310,000 civil asset forfeiture case brought by the U.S. government against a Northern Mariana Islands business after concluding the court lacked jurisdiction.
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March 12, 2025
Starbucks' Sourcing Aided $1.3B Low-Tax Profits, Report Says
Starbucks leveraged its private certification program for coffee growers to boost profits transferred almost tax-free from Switzerland to the Netherlands to the U.K., amounting to an estimated $1.3 billion between 2011 and 2021, according to a report from a union-funded nonprofit organization.
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March 12, 2025
Tariffs Prompt Chipmakers To Look At Manufacturing Moves
The U.S. semiconductor industry is considering moving manufacturing operations to the U.S. and elsewhere as a tariff-mitigation strategy with President Donald Trump threatening to levy the sector and its supply chains, professionals told Law360.
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March 12, 2025
EU E-Commerce Group Calls For Extended DST Moratorium
The expiration of an agreement pausing implementation of digital services taxes comes as the entirety of the OECD's two-pillar agreement on international taxes leaves impacted businesses in uncertain waters, a European Union business group said in a letter, seeking an extension of the moratorium.
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March 12, 2025
EU Targets US Goods In Response To Trump's Tariffs
The European Commission said Wednesday that it will impose tariffs on American goods imported into the European Union in response to U.S. tariffs placed on EU steel and aluminum exports.
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March 12, 2025
Spain Referred To CJEU Over Nonresident Tax Treatment
Spain will have to face the Court of Justice of the European Union over what the European Commission said is a discriminatory capital gains tax regime because of a deferral available to residents that is not available to nonresidents.
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March 12, 2025
HMRC To Reward Whistleblowers Who Expose Tax Fraud
Insiders who tip off investigators to serious tax avoidance by large companies and rich elites will be paid a cut of any money the U.K. tax enforcer claws back under a new policy proposed by the government.
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March 11, 2025
Canada's Incoming PM Pledges To Kill Capital Gains Tax Hike
Canada's newly elected Prime Minister-designate Mark Carney said during his election victory speech that he would spike a controversial proposed increase to the country's capital gains tax, according to local media.
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March 11, 2025
Trump, Ontario Back Down After Two-Day Trade Flare-Up
President Donald Trump called off additional tariffs on Canadian steel and aluminum Tuesday after the Ontario government dropped a briefly imposed surcharge on electricity exports, the White House told Law360 on Tuesday evening.
Expert Analysis
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A Year-End Look At Florida's Capital Investment Tax Credit
Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.
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The Case For Post-Bar Clerk Training Programs At Law Firms
In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.
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AI Can Help Lawyers Overcome The Programming Barrier
Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.
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Preparing Law Students For A New, AI-Assisted Legal World
As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.
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General Counsel Need Data Literacy To Keep Up With AI
With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.
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Navigating Discovery Of Generative AI Information
As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.
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Finding Focus: Strategies For Attorneys With ADHD
Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.
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Attorneys, Law Schools Must Adapt To New Era Of Evidence
Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.
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1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.
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Tips For Litigating Against Pro Se Parties In Complex Disputes
Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.
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Anticipating Intensified Partnership Enforcement From IRS
The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.
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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.