International
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October 06, 2025
London Casino Loses Dispute Over VAT Base Method
HM Revenue & Customs used the correct method for calculating the value-added tax base of a casino, a London court ruled Monday, rejecting the casino's arguments for the use of a special method that would have allowed it to recover more input VAT.
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October 06, 2025
Social Security Chief Adds Duties As Inaugural CEO Of IRS
The current administrator of the Social Security Administration is adding a new role as the Internal Revenue Service's first chief executive officer, Treasury Secretary Scott Bessent announced Monday.
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October 03, 2025
28% Of Large Cos. In Australia Paid No Income Tax Last Year
The share of large companies operating in Australia that paid no income taxes dropped below 30% for the first time during the 2023-2024 period, the Australian Taxation Office said, attributing this to officials curbing tax avoidance.
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October 03, 2025
Indian Gov't Report Floats Fixed Profit Rates For Foreign Cos.
India should revise its permanent establishment rules by introducing an optional scheme to assign fixed profit rates by industry or business model, which would reduce litigation by foreign businesses over profit attribution methods, a government think tank said Friday.
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October 03, 2025
Some Longtime Legal Blogs Go Quiet As Platform Shuts Down
When the online publishing platform Typepad launched more than two decades ago, it became a hub for a then-growing community of law professors and legal bloggers. Its closure this week marked the end of an era that has found some bloggers looking for new homes or opting to call it quits.
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October 03, 2025
DC Circ. Split On Challenge To IRS-ICE Info-Sharing Deal
D.C. Circuit judges seemed split Friday over whether an information-sharing agreement between immigration authorities and the IRS complies with taxpayer privacy protections, with one judge noting during oral arguments that the government immigration arm requesting the tax information appears unauthorized to make the requests.
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October 03, 2025
Getting It Right: An Economist On Transfer Pricing
Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.
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October 03, 2025
Mining Cos. Warn Of OECD Guidance's Transfer Pricing Risks
Mining companies and other stakeholders raised concerns over transfer pricing risks and possible tax disputes arising from proposed guidance on pricing copper exports, according to documents published by the Organization for Economic Cooperation and Development.
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October 03, 2025
Taxation With Representation: Kirkland, Paul Weiss, Cravath
In this week's Taxation With Representation, video game maker Electronic Arts agrees to be acquired by the Saudi Arabia Public Investment Fund, Silver Lake and Affinity Partners; online mortgage giant Rocket closes its acquisition of rival Mr. Cooper Group; and Berkshire Hathaway acquires international energy company Occidental's chemical business.
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October 03, 2025
Denmark's £1.4B Cum-Ex Loss Raises Legal Strategy Doubts
Denmark's "bruising" defeat in its £1.4 billion ($1.9 billion) cum-ex fraud case against trader Sanjay Shah and others calls into question its legal strategy and the scope of its claim, lawyers have said, although they believe an appeal appears inevitable.
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October 03, 2025
Denmark Denied Permission To Appeal £1.4B Cum-Ex Defeat
Denmark cannot revive its £1.4 billion ($1.9 billion) against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.
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October 02, 2025
IRS Data-Sharing Case Won't Be Paused For Gov't Shutdown
The U.S. Department of Justice must still submit court-ordered information in a lawsuit challenging the Internal Revenue Service's sharing of tax data with immigration authorities by Oct. 24, a D.C. federal judge ruled, despite the federal government shutdown that began Wednesday.
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October 02, 2025
German States Push To Halt Min. Tax As US Seeks Exemption
Three German states said they would ask the country's other states Thursday to push the federal government to suspend the 15% global minimum tax in Germany while the U.S. proposal to exempt American companies from most of the system is being resolved.
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October 02, 2025
Debt Recovery Actions Not Taxable Under EU Law, ECJ Says
A holding company pursuing debt recovery is not providing a taxable service to its debtor under European value-added tax law, the European Union's top court ruled Thursday.
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October 02, 2025
Tax KC Sued By Hedge Fund Billionaire Over Negligence
Billionaire Michael Platt and his hedge fund BlueCrest Capital Management have sued a senior One Essex Court barrister who represented them in a dispute with the U.K. tax authority over the identity of awards paid under a special partnership program.
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October 02, 2025
Denmark Loses £1.4B Cum-Ex Fraud Case Against UK Trader
Denmark lost on Thursday its £1.4 billion ($1.9 billion) legal claim against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.
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October 01, 2025
Calif. Importer, Son Both Get Prison For $8M Customs Fraud
A California federal judge sentenced a Los Angeles Fashion District business owner and his son to more than eight years and seven years in prison, respectively, after they were found guilty of ducking more than $8 million in customs duties and failing to report over $17 million in cash transactions on tax returns.
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October 01, 2025
EU Wants To Lead Bloc On UN Tax Treaty's Dispute Section
The European Union's executive branch has asked the bloc's member states to grant it the final say in agreeing to a legally binding protocol on dispute resolution within the United Nations' framework convention on international tax cooperation, saying the matter falls within its responsibilities.
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October 01, 2025
States, Businesses Push Justices To Extend Tariff Arguments
The dozen states, several small businesses and Illinois toymakers that challenged President Donald Trump's emergency tariffs filed a joint motion Wednesday requesting more time to better represent their different claims for oral arguments at the U.S. Supreme Court in November.
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October 01, 2025
NJ Can't Tax Sale Of Stake In Foreign Co., Enterprise Says
Car rental giant Enterprise asked the New Jersey Tax Court to negate a $1.2 million tax assessment stemming from a sale of interest in an Israel-based software company, arguing that the gain was nonoperational income that should be allocated to Enterprise's home state, Missouri, for tax purposes.
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October 01, 2025
Healthcare Training Co. Says Firm's VAT Advice Cost It £2M
An accounting firm gave incorrect advice to a healthcare worker training company on value-added tax registration, the company alleged in a claim filed with a London court, leading to a tax liability of almost £2 million ($2.7 million).
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October 01, 2025
Peru Says Mining Co. Can't Revive $417M Penalty Claim
Peru is resisting an Arizona-based mining company's bid to annul a decision by international arbiters who found they lacked jurisdiction over $417 million in penalties and interest the country imposed for unpaid royalties, saying the company is wrong to claim the issue was improperly ignored.
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October 01, 2025
Caplin & Drysdale Adds Longtime IRS Pro To DC Office
Caplin & Drysdale has grown its Washington, D.C., office with the addition of a veteran Internal Revenue Service attorney, the firm announced Wednesday.
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October 01, 2025
8th Circ. Reverses IRS Win In 3M Transfer Pricing Case
The Eighth Circuit reversed a U.S. Tax Court ruling Wednesday that backed the Internal Revenue Service's decision to reallocate nearly $24 million of 3M Co.'s Brazilian income, holding that the transfer pricing regulations underlying the adjustment are invalid.
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October 01, 2025
Bank CEO Cleared Of Dishonestly Assisting £415M Tax Fraud
A Caribbean bank and its former chief executive have been cleared of dishonestly assisting a £415 million ($558 million) value-added tax fraud as a London court ruled that he did not know about the scheme to defraud tax authorities.
Expert Analysis
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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.
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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.