International
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June 02, 2025
OECD Releases Consolidated Text Of Data-Swap Guidance
The Organization for Economic Cooperation and Development published consolidated text of a global reporting standard Monday to help tax administrations exchange financial information about individuals who may be trying to hide money from their tax authorities at home.
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June 02, 2025
IRS To Hold Hearing On Sourcing Cloud Transaction Income
The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.
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May 30, 2025
US-China Trade Talks Could Resume After Stall Over Minerals
Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.
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May 30, 2025
Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight
An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.
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May 30, 2025
HMRC Correctly Handled Land Tax Dodge, UK Court Says
HM Revenue & Customs followed the correct procedures to collect taxes on six individuals who attempted to dodge the U.K.'s land tax by transacting with a special purpose vehicle in Guernsey, the Upper Tribunal ruled.
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May 30, 2025
Isle Of Man Agrees To Work With UK Against Tax Avoidance
Isle of Man authorities reached an agreement with the U.K. government to work together in a crackdown on promoters of tax avoidance schemes, according to a joint statement.
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May 30, 2025
UK Midsize Biz Owners Wary Of Risk Exposure, Report Says
Owners and operators of midsize U.K. businesses are just as wary of risk exposure in personal taxes as they are in business taxes except under certain circumstances, according to a report commissioned by HM Revenue & Customs.
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May 30, 2025
Taxation With Representation: Kirkland, Cravath, Latham
In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.
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May 29, 2025
DC Court Blocks Trump's Tariffs As Overreach Of Power
The International Emergency Economic Powers Act does not empower the president to impose tariffs, the D.C. federal district court said Thursday, ruling that President Donald Trump's global levies are unlawful and barring his administration from enforcing them on two toymakers who challenged the policies.
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May 29, 2025
Fed. Circ. Revives Trump Tariffs As It Weighs Appeal
The Federal Circuit temporarily reinstated President Donald Trump's global tariffs Thursday, a day after the U.S. Court of International Trade held that an emergency law did not give the president "unbounded authority" to impose the measures.
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May 29, 2025
Australia Outlines Compliance For Thin Capitalization Test
The Australian Taxation Office is looking for feedback on draft compliance guidance for corporations looking to use one of its new thin capitalization tests as they relate to cross-border financing arrangements, it said Thursday.
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May 29, 2025
£2.4B Employment Tax Credit Has Limited Value, Report Says
A U.K. employment tax credit worth around £2.4 billion ($3.2 billion) a year in payroll tax relief for businesses has limited value, according to a report commissioned by HM Revenue & Customs, with the smallest businesses reaping the most benefit.
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May 29, 2025
Biz Group Calls On EU To Resolve Pillar 2 Dispute With US
The European Union should work quickly to resolve problems with the Pillar Two global minimum corporate tax and its interaction with the U.S. tax system, the American Chamber of Commerce for the EU said.
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May 29, 2025
IRS Annual Gross Collections Top $5 Trillion For First Time
The Internal Revenue Service collected $5.1 trillion in gross revenue in fiscal year 2024, a 9% increase over last year's $4.7 trillion total, marking the first time the tax haul has been above $5 trillion, the agency said Thursday.
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May 29, 2025
US Tariffs Spark Profit Warnings For UK Pension Sponsors
British businesses might seek to tap into pension surpluses because of ongoing financial losses caused by U.S. tariffs, a professional services firm has warned.
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May 28, 2025
International Trade Court Strikes Down Trump's Tariffs
The International Emergency Economic Powers Act does not give the president the "unbounded authority" to impose tariffs on goods from nearly every country in the world, the U.S. Court of International Trade ruled Wednesday, handing a win to small businesses and states challenging some of President Donald Trump's steep tariffs.
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May 28, 2025
Fintech Group Warns Remittance Tax Will Hurt Consumers
The American Fintech Council sent a letter to members of Congress asking them to reconsider a proposed tax on remittances that is a part of the $3.8 trillion bill to extend and make permanent the Republican Party's 2017 tax overhaul law, also known as The One Big Beautiful Bill Act.
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May 28, 2025
4 Big Questions Raised By International Retaliatory Tax In GOP Bill
Republicans' evolving international retaliatory tax proposal has been viewed as an effort to influence foreign tax regimes and as a possible tool in global tax and trade talks, but it has sparked concerns that it could escalate a trade war or otherwise hurt the U.S. economy. Here, Law360 explores four questions raised by the proposal.
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May 28, 2025
$3.9 Trillion Price Tag On House Budget Bill's Tax Provisions
Tax provisions included in the House-passed budget reconciliation bill that would extend and make permanent many provisions in the 2017 tax overhaul would cost $3.9 trillion over the next decade, according to a report released Wednesday by the Joint Committee on Taxation.
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May 28, 2025
Mexico Collected $982M From Transfer Pricing Last Year
Mexico's transfer pricing regime collected 19 billion pesos ($980 million) from large businesses last year, part of a trend that has seen the country's transfer pricing revenue more than triple over the past five years compared with the prior five-year period, its tax administration said.
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May 28, 2025
One Convicted For Role In €195M VAT Fraud Scheme
A Munich court convicted a man for his role in a value-added tax fraud scheme that spanned 17 countries and caused an estimated €195 million ($220 million) in damages, the European Public Prosecutor's Office said Wednesday.
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May 28, 2025
Fried Frank Adds KPMG International Tax Ace In NY
Fried Frank Harris Shriver & Jacobson LLP has hired a KPMG international tax group principal as a tax partner in New York.
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May 28, 2025
EU Proposes Simplified Tax Rules For Remote Workers
The European Commission set out proposals Wednesday to simplify tax rules for remote employees and cross-border work arrangements in a policy paper, as part of a regime to remove barriers for businesses across the European Union.
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May 28, 2025
Hong Kong Adopts OECD's Global Minimum Tax
Hong Kong's government has implemented the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities, expecting it to soon generate HK$15 billion ($1.9 billion) annually, its Inland Revenue Department said Wednesday.
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May 28, 2025
UK Eyes Cutting Pension Tax Breaks To Boost Revenue
The government could be considering the removal of tax breaks on workplace pensions salary-sacrifice plans, experts have warned, as part of an effort to increase revenue in the next budget.
Expert Analysis
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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.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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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.