International
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June 17, 2025
AbbVie Can Get Deduction For $1.6B Payment, Tax Court Says
AbbVie can claim a deduction for the $1.6 billion it paid under a merger agreement, the U.S. Tax Court held Tuesday, rejecting the IRS' contention that the payment was a capital loss that raised the pharmaceutical giant's tax bill by $572 million.
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June 17, 2025
Ill. Toy Makers Seek Justices' Early Review Of Trump Tariff Suit
Illinois-based toy makers challenging President Donald Trump's emergency tariffs on Tuesday requested the U.S. Supreme Court consider their case before it is reviewed by the D.C. Circuit, arguing a stay to an injunction is allowing duty collections to continue and is damaging the companies.
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June 17, 2025
DOJ Seeks 5 Years, $10M For Fla. Man Hiding Swiss Accounts
A Miami man who lied to authorities and others for decades about his Swiss bank accounts should pay $10.3 million in unpaid taxes and face a maximum five-year prison sentence based on his plea agreement, the U.S. Department of Justice told a Florida federal court.
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June 17, 2025
Poland Calls For EU Digital Services Tax In Revenue Package
The European Commission should consider previous proposals for a digital services tax regime across the European Union as part of its revenue package, the Polish presidency of the Council of the EU said in a report.
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June 17, 2025
Tax Admins In OECD Group Largely Using AI, Report Says
Of the 54 members of the OECD's Forum on Tax Administration, over 70% are using artifical intelligence in some way to improve services, most often to detect tax evasion and fraud, the OECD said in a report Tuesday.
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June 17, 2025
IRS Updates Prefiling Program For Large Biz, Int'l Taxpayers
The Internal Revenue Service has made several changes to its prefiling agreement program, including updating the guidelines to help large corporate and international taxpayers flag potential issues before submitting returns, the agency said Tuesday.
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June 17, 2025
Swedish Tax Agency Asks For Greater Enforcement Powers
The Swedish Tax Agency is looking to enhance its ability to address tax crimes, it told the country's Ministry of Finance on Tuesday, sharing proposals that would strengthen its law enforcement powers and grant it the power to store biometric data.
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June 17, 2025
Norway Looks To Adopt Updated Pillar 2 Guidance
The Norwegian Ministry of Finance proposed updating its adoption of the Organization for Economic Cooperation and Development's global minimum tax to integrate administrative guidance issued over the past year.
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June 17, 2025
HMRC Challenges Tax Treatment Of Partnership Awards
HM Revenue & Customs told the U.K. Supreme Court on Tuesday that partnership awards allocated to a corporate entity and then distributed to partners should be taxed as if they were allocated to individual members.
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June 16, 2025
US, UK Reach Trade Deal On Cars; Steel Tariffs Still Unresolved
President Donald Trump signed an order Monday enshrining the nation's new trade deal with U.K. governments under which the U.S. agreed to slash tariffs on 100,000 imported U.K. automobiles and auto parts, while eliminating tariffs on certain aerospace products but leaving steel and pharmaceuticals tariffs for future negotiations.
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June 16, 2025
Senate Bill Sticks With TCJA's $10,000 SALT Cap
The Senate Finance Committee's tax portion of the chamber's budget reconciliation bill released Monday follows the House's lead on some provisions while breaking with the lower chamber's hard-won compromises on an increased state and local tax deduction and the phaseout of green energy credits.
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June 16, 2025
The Tax Angle: EITC Audits, UTPR, Energy Credits
From a look at Republicans' efforts to audit the earned income tax credit, complaints about unfair foreign taxation under the OECD's Pillar Two framework and Democrats' push against Republican plans to strip the Inflation Reduction Act's energy credits from the code, here's a peek into a reporter's notebook on a few developing tax stories.
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June 16, 2025
Book Profits Much Higher Than Taxable Income, Paper Says
Companies report about three to four times higher profits on financial statements for investors compared with the taxable income they report to authorities, a phenomenon most prevalent among multinational corporations, which suggests book profits underestimate profit shifting, the EU Tax Observatory said Monday.
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June 16, 2025
G7 Could Raise $214B Yearly From 2% Wealth Tax, Group Says
The Group of Seven countries could raise $214 billion a year if each government imposed a 2% wealth tax on fortunes above $100 million, with the U.S. potentially raising $161 billion by itself, a group of wealthy Canadians said Monday in support of such measures.
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June 16, 2025
Trump Eyes Trade Deal With Canada During G7 Summit Talks
President Donald Trump said at the G7 summit Monday that he would work with Canadian Prime Minister Mark Carney to reach a trade deal, raising the possibility that an agreement could be struck before the multilateral meeting concludes.
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June 16, 2025
Wealth Taxes, End Of Profit Shifting Worth $2.6T, Group Says
World governments could raise about $2.6 trillion annually, more than enough revenue to finance most climate-related needs, if they collectively adopted low-rate wealth taxes beginning with the richest 0.5% and stopped multinational corporations from shifting profits, the Tax Justice Network said Monday.
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June 16, 2025
HMRC Warns Umbrella Co. Employees Of Tax Risks
Employees and contractors of temporary worker agencies known as umbrella companies need to be vigilant to make sure they aren't unwittingly involving themselves in tax avoidance schemes, HM Revenue & Customs said, laying out ways to spot such avoidance issues.
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June 16, 2025
OECD Offers Template For Tax Crime Investigation Guidance
The Organization for Economic Cooperation and Development released standards Monday for jurisdictions to use when creating manuals to guide government agencies through tax crime investigations, with the aim of creating more efficient and effective processes, it said.
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June 16, 2025
Colombian Taxpayers Owe $34M In Foreign Exchange Debts
Nearly 290 Colombian taxpayers have accumulated roughly 142.2 billion Colombian pesos ($34.6 million) in unpaid tax debts related to their foreign exchange transactions, the country's tax authority said, offering possible reductions for their associated penalties.
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June 13, 2025
US-China Trade Talks Resume, Draw Mixed Reviews
Despite the promise of new trade talks held this week by the U.S. and China, the long-term strategic view of many companies remains concern over the obstacles they continue to face, especially if they must diversify supply chains that heavily rely on China.
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June 13, 2025
211K Suspicious Transaction Reports Filed In France In 2024
France's anti-money laundering unit received over 211,000 reports of suspicious financial transactions in 2024, making up the vast majority of the more than 215,000 reports received by the unit, an over 13% increase from the year prior, the country's finance ministry said Friday.
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June 13, 2025
Israeli Businessman Found Liable For $3.2M Over FBARs
An Israeli businessman who was held in contempt of court for dodging discovery requests is liable for $3.24 million in penalties and interest for willfully failing to report his foreign bank accounts, according to a Washington federal court.
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June 13, 2025
UK Businessman Defends Asset Transfer As Tax Strategy
A British businessman denied that he transferred a company to his son to defraud a creditor, arguing it was part of a long-term tax strategy rather than a tactic to avoid repaying £4.7 million ($6.4 million) in debt.
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June 13, 2025
Tax Credit Sales Would Be Difficult To Insure Under House Bill
House Republicans' sweeping budget bill proposes to promptly scale back the clean energy tax incentives established by the 2022 climate law, a move that would make it difficult for tax insurers to back project development deals that want to sell their tax credits for cash.
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June 13, 2025
Taxation With Representation: Debevoise, Latham, Paul Weiss
In this week's Taxation With Representation, Brown & Brown Inc. buys Accession Risk Management Group Inc., Allison Transmission Holdings Inc. acquires Dana Inc.'s off-highway unit, Qualcomm Inc. buys Alphawave IP, and Warner Bros. Discovery announced it will split into two publicly traded companies.
Expert Analysis
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So You Want To Move Your Law Practice To Canada, Eh?
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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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
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As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
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Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
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The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
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Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.