International
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March 21, 2025
Spanish Lottery Co. Accused Of Tax Insurance Market Breach
Spain's competition authority said Friday it is investigating a lottery company on suspicion of suppressing the marketing of tax insurance coverage for lottery winners.
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March 20, 2025
Corp. Taxes Should Match Climate Goals, OECD Paper Says
Countries that want to reduce carbon emissions should design corporate income taxes that align with climate policy objectives, including providing incentives for clean energy investments, according to an OECD working paper released Thursday.
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March 20, 2025
Frost Brown Adds Former Houston City Atty To Finance Team
Frost Brown Todd LLP announced that it has hired an attorney from the ranks of Houston's city government to strengthen its public finance group, adding his expertise in state and local government operations, taxation and economic development.
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March 20, 2025
PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.
Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified.
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March 20, 2025
90% Of Crypto Sellers Conceal Income, Danish Data Shows
Danish Tax Agency data shows more than 90% of cryptocurrency sellers don't report that income and that many have shifted to foreign platforms to avoid domestic reporting rules, the EU Tax Observatory said in a working paper, suggesting international coordination is essential to tax crypto effectively.
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March 20, 2025
Prudential's £9.3M Fees To Silverfleet Taxable, HMRC Argues
Prudential's payments of £9.3 million ($12 million) to an investment firm are taxable even though the fees were for services the firm carried out when the two companies were part of the same group, the tax authority's counsel told the U.K. Supreme Court on Thursday.
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March 19, 2025
IRS Hunter Biden Whistleblower Named Deputy Criminal Chief
An Internal Revenue Service special agent who accused the U.S. Department of Justice of mishandling an investigation into former President Joe Biden's son has been named deputy chief in the IRS Criminal Investigation division, the agency said Wednesday.
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March 19, 2025
Coke's $2.7B Tax Bill Arbitrary, Business Groups Tell 11th Circ.
Three industry groups asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming that the Internal Revenue Service could raise Coca-Cola's taxes by $2.7 billion, saying in friend-of-the-court briefs that the IRS acted arbitrarily in hiking the Atlanta-based beverage giant's tax liability.
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March 19, 2025
Sweden Proposes Cutting Some Green Energy Tax Breaks
Sweden's Ministry of Finance is proposing that the government slash a pair of green energy tax benefits, one for the installation of solar panels and the other related to the microproduction of renewable energy.
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March 19, 2025
Technical, Policy Questions Still Swirl Around Amount B
U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.
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March 19, 2025
DC Judge Won't Preemptively Stop IRS Data Sharing With DHS
A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their bid for a court order that would preemptively block any information transfer.
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March 19, 2025
Switzerland, Zimbabwe Sign Tax Treaty
Switzerland and Zimbabwe signed an agreement Wednesday for a treaty to avoid double taxation of income, an expansion of the Swiss treaty network in southern Africa that has been welcomed by cantons and businesses, according to Switzerland's competent authority.
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March 19, 2025
Law360 Announces The Members Of Its 2025 Editorial Boards
Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.
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March 19, 2025
Group Status Prohibits VAT, Prudential Tells UK Top Court
Prudential disputed a value-added tax claim on £9.3 million ($12.1 million) in performance fees at the U.K. Supreme Court on Wednesday on the grounds that the business providing the services was a part of the same group as Prudential for tax purposes.
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March 19, 2025
Ex-Glencore Exec Fights £150M Tax On Offshore Shares
Glencore's former head of oil urged an appeals court Wednesday to overturn a finding he was liable for income tax on nearly £150 million ($194 million) in share distributions from the Jersey company, in a case that could have wide implications on U.K. shareholders of offshore businesses.
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March 19, 2025
Disclosure Woes Sink £13M Fraud Trial Against Film Execs
Prosecutors have abandoned a decade-long fraud case in which four former managers at a film production company were accused of cheating taxpayers out of £13 million ($17 million) because of insurmountable disclosure failures that sunk the case mid-trial.
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March 18, 2025
Tax Court Sides With IRS Deeming Debt 'Seriously Delinquent'
A Florida man's tax debt was property certified by the Internal Revenue Service as "seriously delinquent" and reported to the U.S. secretary of state to bar him from obtaining or renewing a passport, the U.S. Tax Court said Tuesday.
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March 18, 2025
Danish Wind Farm Co. Wins UK Tax Relief For Study Costs
A Danish wind farm company can claim expenditures on studies and designs associated with constructing wind farms for tax relief purposes, a London appeals court ruled.
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March 18, 2025
5 Jurisdictions Must Improve Tax Transparency, OECD Says
Djibouti, the British Virgin Islands and three other jurisdictions have work to do to improve their compliance with global standards for tax transparency and exchange-of-information measures, according to reports published Tuesday by the Organization for Economic Cooperation and Development.
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March 18, 2025
Trump Hasn't Asked IRS For Immigrants' Tax Info, Gov't Says
The IRS hasn't received any requests from President Donald Trump for immigrants' tax return information and hasn't released any such information to the U.S. Department of Homeland Security, the government told a D.C. federal court in opposing a restraining order sought by immigrant rights groups.
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March 18, 2025
Microsoft Cost-Share Receipts Tax Fight Sent To Trial In Mich.
Microsoft's challenge to Michigan's tax treatment of its cost-sharing agreement receipts is headed to trial after the state's tax tribunal said more proceedings are necessary to determine whether the ownership of the intellectual property in dispute is divided between the company and its affiliates.
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March 18, 2025
EU To Push On With OECD Tax Plan, Official Says
The European Union remains committed to the two-pillar international tax plan designed by the Organization for Economic Cooperation and Development despite U.S. opposition, the EU's tax commissioner said Tuesday.
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March 18, 2025
Canadian PM Candidate Says He'd End Carbon Pricing
Canada's Conservative Party leader and head opposition candidate for prime minister in an upcoming election said he would end the country's nationwide pricing system for greenhouse gas emissions if elected.
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March 17, 2025
Florida Businessman Pleads Guilty To Hiding $20M From IRS
A Florida businessman faces up to five years in prison after he pled guilty Monday to hiding $20 million in Swiss bank accounts from the Internal Revenue Service.
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March 17, 2025
The Tax Angle: Lawmakers Huddle To Mull TCJA
From a look at the three-day legislative retreat held by House Democrats to Ways and Means Republicans meeting behind closed doors to discuss the 2017 GOP tax overhaul, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
Expert Analysis
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
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5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.