International
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October 27, 2025
Accounting Firm Denies Liability For Investor's £633K Tax Bill
An accountancy firm has denied an investor's accusations that it was negligent in giving tax planning advice that resulted in him being hit with a £633,000 ($844,217) liability assessment, saying he had failed to distinguish between two tax schemes.
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October 27, 2025
Director Misused Confidential Info To Market Tax Scheme
A London court has ruled that the director of a tax-efficient investment product company misused confidential information by taking features of an accountant's money-saving tax structure to market in breach of a nondisclosure agreement.
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October 24, 2025
Former Judges Tell Justices To Strike Down Trump's Tariffs
Former federal judges and government officials, joined by scholars, economists, businesses and interest groups, told the U.S. Supreme Court this week that President Donald Trump's emergency tariffs should be struck down because the law the president has utilized does not give him power to impose those measures.
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October 24, 2025
Tax Pros Expect No IRS Word Soon On 'Friendly Doctor' Deals
The tax treatment of private equity investments in medical firms and other professional practices remains unresolved as the Internal Revenue Service delays updates to long-awaited consolidated return regulations and focuses instead on implementing the new 2025 Republican budget law, tax experts said Friday.
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October 24, 2025
USTR To Probe China's Adherence To 2020 Trade Deal
The Office of the U.S. Trade Representative opened an investigation Friday into China's adherence to a 2020 trade deal after determining there has been an "apparent failure to comply" with its terms, an accusation disputed by a Chinese government representative who spoke with Law360.
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October 24, 2025
Trump Ends Canada Trade Talks Over Ontario's Reagan Ad
President Donald Trump said he ended trade negotiations with Canada because of an advertisement by Ontario's provincial government featuring critical remarks about tariffs by President Ronald Reagan.
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October 24, 2025
Taxation With Representation: Latham, Wachtell, Gibson Dunn
In this week's Taxation With Representation, Meta announces a joint venture with Blue Owl Capital to fund the development of a data center campus in Louisiana, private equity giants acquire medical technology company Hologic Inc., and National Fuel Gas Co. buys CenterPoint Energy Inc.'s Ohio natural gas utility business.
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October 24, 2025
Talks On Shipping Carbon Price Continue Despite Plan's Delay
The United Nations' maritime agency continued talks on the details of a global carbon price plan for shipping this past week despite the recent postponement of the plan amid U.S. opposition, experts taking part in the process said Friday.
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October 23, 2025
French Legislators Advance 15% DST To Mirror US Tariffs
France's digital services tax rate would rise from 3% to 15% under an amendment adopted by the lower house of Parliament's Finance Committee, which characterized the action as a "proportionate response" to tariffs imposed by the United States.
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October 23, 2025
US Oil Cos. Pay More Tax Abroad Than At Home, Report Says
American oil and gas companies with foreign extraction operations paid more than 80% of their total taxes abroad in recent years despite producing more oil and gas in the U.S. than everywhere else combined, a corporate transparency group said Thursday.
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October 23, 2025
IRS To Float Sourcing Rules For Certain Securities Loans
The Internal Revenue Service said Thursday it intends to propose regulations that would have it look to the borrower of certain securities, rather than the lender, when determining whether related payments are sourced from the United States.
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October 23, 2025
Law Firms Could Face £1.4B Bill Under Rumored Tax Change
Partners at law firms face paying up to £1.4 billion ($1.9 billion) more in tax each year if the government imposes a new tax on limited liability partnerships to help plug a hole in Britain's finances, UHY Hacker Young said Thursday.
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October 23, 2025
UK Court Denies Leisure Firm's Bid For Extra VAT Interest
A leisure services company can't claim additional interest of £8.2 million ($11 million) on value-added tax overpaid to HM Revenue & Customs because statutory interest provided full compensation, a British court ruled.
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October 23, 2025
Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion
Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.
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October 23, 2025
Ex-Clifford Chance Pro Hit With £8M Libel Claim By Barrister
A barrister has sued legal commentator Dan Neidle and his think tank for £8 million ($10.6 million), accusing the former Clifford Chance partner of engaging in a vendetta against him, according to court filings that have now been made public.
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October 22, 2025
Australia Issues Guidance For Minimum Tax Safe Harbor
Australia released guidance Wednesday detailing when companies can forgo detailed top-up tax calculations for a jurisdiction under a safe harbor for the 15% global minimum tax that is based on country-by-country reporting.
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October 22, 2025
US Among Few Places With Amount B Rules, OECD Reports
The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.
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October 22, 2025
'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says
Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.
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October 22, 2025
Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling
Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.
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October 22, 2025
Trade Court OKs $235K Tax Bill On Korean Soju Imports
South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.
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October 22, 2025
Canada Tax Agency Could Expand Audit Powers, Pro Says
Tax attorneys in Canada are closely watching a proposal that would give the country's revenue agency extensive audit powers, including the ability to take information under oath before any potential litigation begins, a practitioner said Wednesday.
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October 22, 2025
Switzerland Seeks Comments On Updated EU Tax Data Deal
The Swiss government is inviting public comments on an agreement it reached with the European Union to update the jurisdictions' agreement for the automatic exchange of tax information, it said Wednesday.
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October 21, 2025
Discovery Against Gem Company Halted In Malawi's Tax Probe
Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.
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October 21, 2025
'Revenge Tax' May Reappear If Pillar 2 Talks Stall, Pros Say
Republican lawmakers are likely to revive what is commonly known as the revenge tax if countries are unable to flesh out a tentative agreement to effectively exempt U.S. companies from the 15% global corporate minimum tax regime known as Pillar Two, practitioners said Tuesday.
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October 21, 2025
EU To Ditch Plans For Transaction Tax, Shell Co. Law
The European Commission plans to withdraw proposed directives that would impose a financial transaction tax and target tax evasion through the use of shell companies, it said Tuesday in a work program for 2026.
Expert Analysis
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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.
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In-House Counsel Pointers For Preserving Atty-Client Privilege
Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.
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Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example
Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.
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Accountant-Owned Law Firms Could Blur Ethical Lines
KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.
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AI Will Soon Transform The E-Discovery Industrial Complex
Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.
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Unpacking The Legal Foundation Of Trump's New Trade War
President Donald Trump's recent executive orders and proclamations regarding emergencies at the U.S. border are based on statutory powers enabling a president to address extraordinary external threats — and could be used to fend off legal challenges to the tariffs levied on Mexican and Canadian goods, says Chris Zona at Mandelbaum Barrett.
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When Innovation Overwhelms The Rule Of Law
In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.
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Imagine The Possibilities Of Openly Autistic Lawyering
Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.
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Litigation Funding Disclosure Debate: Strategy Considerations
In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.
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5 Ways To Create Effective Mock Assignments For Associates
In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.
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Mentorship Resolutions For The New Year
Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.
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Tax Directive Marks Milestone In Harmonizing EU System
The Council of the European Union’s recently adopted tax directive is a significant step toward streamlining and modernizing procedures for member states, and will greatly reduce administrative burden and compliance costs for cross-border investors, says Martin Phelan at Simmons & Simmons.