International

  • August 12, 2025

    Federal Revenue From Customs Duties Sharply Higher In July

    The federal government raised $28 billion from customs duties, including tariffs, during July, accounting for about 8.3% of federal revenues that month, compared with an average of around 2% in recent history, the U.S. Department of the Treasury reported Tuesday.

  • August 12, 2025

    Ex-PwC Partner Temporarily Banned From Aussie Tax Work

    A former PwC partner is temporarily banned from providing tax services in Australia after authorities determined he made false statements when seeking research and development tax credits, which caused a tax shortfall of over AU$11 million ($7 million), Australia's Tax Practitioners Board said Tuesday.

  • August 11, 2025

    Data Co. Asks DC Circ. To Revive $22M Guinea Award Bid

    A data consulting company has again urged the D.C. Circuit to reverse a lower court order denying its bid to enforce a $22 million arbitral award against Guinea, saying the country wrongly wants the appeals court to ignore long-standing precedent and nix enforcement on jurisdictional grounds.

  • August 11, 2025

    Tax Court Backs IRS' Denial Of Whistleblower's Award Bid

    A whistleblower was correctly denied an award for information about alleged underpayments by a large multinational corporation, the U.S. Tax Court said Monday, finding the information did not substantially contribute to the IRS' action in the case.

  • August 11, 2025

    Gov'ts Mull Gross Basis Tax For Services In UN Convention

    A number of developing countries argued Monday that gross basis taxation is the easiest-to-administer option for overcoming inequitable transfer pricing rules within a protocol on taxing cross-border services in the United Nations framework convention on international tax cooperation.

  • August 11, 2025

    Goodyear Facing Tax Adjustments Over Intercompany IP Sale

    Goodyear Tire & Rubber Co. is planning to challenge proposed IRS adjustments that could undermine the company's ability to offset certain taxes related to an intercompany intellectual property sale, according to a U.S. Securities and Exchange Commission filing.

  • August 11, 2025

    6th Circ. Orders Eaton To Give Employee Records To IRS

    The Sixth Circuit affirmed an Ohio federal judge's order requiring Eaton Corp. to share performance evaluations for Ireland-based workers with the IRS, holding that the agency's interest in investigating potential tax liabilities outweighs Ireland's privacy interest, which the court said was "weak" at best.

  • August 11, 2025

    Kostelanetz Hires Most Recent DOJ Tax Division Leader

    The immediate past head of the U.S. Department of Justice's Tax Division will join Kostelanetz LLP as a partner in Washington, D.C., amid a sweeping restructuring that would split the division's criminal and civil tax functions and place them in the department's main branches.

  • August 11, 2025

    2nd Circ. Affirms Denial Of Partnership's $22.7M Tax Loss

    The U.S. Tax Court correctly found the IRS properly denied a Connecticut partnership's $22.7 million loss deduction because the underlying transactions, which involved a Brazilian company, were tantamount to a disguised property sale, the Second Circuit ruled Monday.

  • August 08, 2025

    DC Circ. Hands Banker's Estate Win In IRS Whistleblower Bid

    A split D.C. Circuit sided with the estate of a former banker at Rabobank in ruling Friday that the Internal Revenue Service used the wrong legal standard to deny him an award for contributing to investigations into two companies' tax avoidance scheme.

  • August 08, 2025

    Trump Ousts IRS Commissioner Weeks After Confirmation

    Billy Long has been removed from his role as Internal Revenue Service commissioner after spending just shy of two months as head of the agency, the White House said Friday.

  • August 08, 2025

    Italy Cuts Corporate Tax Rate For Capital Goods Investment

    Italy began offering a lower corporate tax rate Friday to companies that invest in capital goods, including those that reduce energy consumption, or in hiring new employees, provided they don't lay off workers in either case, according to the Economy and Finance Ministry.

  • August 08, 2025

    South Korea Probes 49 Foreign Luxury Apartment Buyers

    South Korea's National Tax Service said it has launched a tax evasion probe into 49 owners of high-priced apartments who are from foreign countries such as the U.S. and China.

  • August 08, 2025

    Swiss Metals Group Fears US Tariffs' Impact On Gold

    The U.S.-imposed 39% tariffs on Switzerland may "negatively impact" gold trading, a Swiss metals association warned Friday.

  • August 08, 2025

    11th Circ. Vacates Russian Gas Ex-CFO's Tax Crime Sentence

    The Eleventh Circuit vacated a Russian former gas executive's seven-year prison term and order to pay $4 million in restitution to the IRS, saying federal prosecutors were wrongly given extra time to bring charges against him for failing to file income tax returns.

  • August 08, 2025

    Australia Lifts PwC Bid Ban, Citing Changes After Tax Leak

    PwC Australia is no longer banned from bidding on government contracts now that the firm has shown "ethical soundness" after a scandal involving the leak of government tax documents, the Australian Department of Finance said Friday.

  • August 08, 2025

    Taxation With Representation: Latham, Alston & Bird, Orrick

    In this week's Taxation With Representation, fiber optic connector systems maker Amphenol Corp. buys CommScope's connectivity and cable solutions business, Blackstone acquires Enverus from private equity firms, investors buy a majority stake in medical device company HistoSonics Inc., and ESPN swaps an equity stake for the National Football League's NFL Network and other intellectual property.

  • August 08, 2025

    Germany Seeks Comments On Amendments To Minimum Tax

    Germany is looking for comments on amendments to its 15% minimum tax, including on changes to how deferred tax assets are treated and on the elimination of an anti-avoidance rule limiting deductions for licensing expenses, the Finance Ministry said Friday.

  • August 08, 2025

    Midyear Review: A Look At The Tax Trends Shaping 2025

    Tax professionals had a lot to keep up with in the first half of 2025, from congressional action to extend the 2017 GOP tax overhaul to a tumultuous international trade scene. And the back half of the year is poised to be just as busy, with litigation over how the IRS handles employee retention tax credits, an Amazon suit in South Carolina over sales tax, and an uncertain future for global minimum tax rules. Here, dive into our slate of analysis pieces to help guide you through evolving tax litigation and policy. 

  • August 07, 2025

    Toyota Forecasts $9.5B Annual Hit From US Tariffs

    U.S. tariffs would cost Toyota Motor Corp. 1.4 trillion yen ($9.5 billion) during its fiscal year ending March 2026, including 450 billion yen in its first quarter, the automaker said Thursday.

  • August 07, 2025

    Siemens Contests Nix Of $315M Foreign-Dividend Tax Break

    Regulatory missteps caused the IRS to wrongly slash $315 million from a foreign-dividend tax deduction Siemens claimed on shareholder payments it received from an overseas affiliate, the medical giant told the U.S. Tax Court.

  • August 07, 2025

    Switzerland Says 39% Tariff Hits Over Half Of Exports To US

    More than half of Switzerland's exports to the United States are now impacted by a 39% tariff, the Swiss government said Thursday after the country's president left Washington, D.C., pledging to continue negotiations to reduce the rate.

  • August 07, 2025

    Hodgson Russ Adds Former NY Tax Pros To SALT Group

    Hodgson Russ LLP has announced that two former New York state and city tax professionals have joined the firm's state and local tax practice in New York City, advising the team on complex regional tax issues.

  • August 07, 2025

    India, Russia Sign Trade Pact As US Hits India For Buying Oil

    India and Russia agreed to deepen their economic ties the same day the United States set into motion tariffs on India for purchasing Russian oil, the Indian government announced.

  • August 07, 2025

    HMRC Aims To Improve Data Access For Tax Research

    HM Revenue & Customs could achieve its goal of making tax data more easily accessible to other government bodies and external researchers in part by improving its existing anonymized data production service, the agency said Thursday.

Expert Analysis

  • An Associate's Guide To Career Development In 2025

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    As the new year begins, associates at all levels should consider establishing career metrics, fostering key relationships and employing other specific strategies to help move through the complexities of the legal profession with confidence and emerge as trailblazers, say EJ Stern and Amanda George at Fractional Law Firm.

  • Making The Pitch To Grow Your Company's Legal Team

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    In a compressed economy, convincing the C-suite to invest in additional legal talent can be a herculean task, but a convincing pitch — supported by metrics and cost analyses — may help in-house counsel justify the growth of their team, say Elizabeth Smith and Roger Garceau at Major Lindsey.

  • Tax Court Should Update Framework For Defining Insurance

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    ​​​​​​​The U.S. Tax Court's unnecessary determination in Royalty Management Insurance v. Commissioner that a fraudulent transaction did not contain the hallmarks of a legitimate insurance transaction applies an outdated analysis that threatens the captive insurance sector and illustrates the need for a more modern framework to define true insurance, says Matthew Queen at the Queen Firm.

  • When US Privilege Law Applies To Docs Made Outside The US

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    As globalization manifests itself in disputes over foreign-created documents, a California federal court’s recent trademark decision illustrates nuances of both U.S. privilege frameworks and foreign evidentiary protections that attorneys must increasingly bear in mind, say attorneys at Hunton.

  • Impact Of Corporate Transparency Act Ambiguity On Banks

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    Even though banks generally needn't file beneficial ownership information reports, financial institutions must continue to monitor the status of the Corporate Transparency Act and understand its requirements in case the nationwide injunction that was issued against the CTA earlier this month is overturned, say attorneys at Armstrong Teasdale.

  • 6 Changes I Would Make If I Ran A Law School

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    Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.

  • Firms Still Have The Edge In Lateral Hiring, But Buyer Beware

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    Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.

  • Think Like A Lawyer: 1 Type Of Case Complexity Stands Out

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    In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.

  • Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity

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    Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Reframing Document Review

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    For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.

  • 3 Ways To Train Junior Lawyers In 30 Minutes Or Less

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    Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.

  • The Bar Needs More Clarity On The Discovery Objection Rule

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    Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.

  • So You Want To Move Your Law Practice To Canada, Eh?

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    Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.

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