International
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May 16, 2025
Tax Dodging By Wealthy Larger Than Thought, UK Body Says
The scale of tax avoidance and evasion by the wealthy could be much greater than the U.K. tax authority previously thought, according to a report by the National Audit Office published Friday.
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May 16, 2025
Taxation With Representation: Blakes, Davies, Goodmans
In this week's Taxation With Representation, Charter Communications Inc. merges with Cox Communications, Hub International Ltd. boosts its valuation after securing an investment, Pan American Silver Corp. acquires Mag Silver Corp. and Robinhood buys WonderFi.
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May 16, 2025
Carbon Taxes Cut Emissions Best In Many Areas, OECD Says
Carbon taxes reduced greenhouse gas emissions from the energy sector, transportation, buildings and agriculture on average more effectively than most other climate policies in a large batch of studies reviewed by the Organization for Economic Cooperation and Development, the group said.
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May 15, 2025
UK To Codify Extensions For Cos. That End VAT Registration
HM Revenue & Customs will have a regulatory basis to grant businesses canceling their value-added tax registration extensions for submitting their final tax return documents under a new measure, codifying a practice it routinely carries out now through administrative concession.
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May 15, 2025
IRS Reopens Comment Period For Offshore Profit Regs
The Internal Revenue Service on Thursday reopened the comment period for proposed rules that would require U.S. multinational companies to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits.
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May 15, 2025
House Tax Bill's Foreign Rules May Finish Off Energy Perks
House Republicans' mammoth tax bill proposes phasing out two popular clean electricity business tax credits, but additional restrictions on eligible development projects' foreign business ties could have the same effect as immediately repealing them.
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May 15, 2025
Pillar Two Costs May Outweigh Revenue, Tax Exec Says
The administrative requirements for complying with an international minimum tax agreement known as Pillar Two could end up costing companies more than any taxes they pay under the global regime, a Microsoft tax executive said Thursday.
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May 15, 2025
House Plans Vote On Budget Bill With Tax Package Next Week
Republican leaders in the House plan to hold a vote next week on the chamber's budget bill that includes the GOP's $3.8 trillion tax package, with the aim of sending the legislation to the Senate before Memorial Day, Ways and Means Committee Chairman Jason Smith said Thursday.
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May 15, 2025
HMRC Fights To Keep £261M In Overseas Dividends Tax Battle
The British High Court was wrong to find BAT Industries PLC could have discovered that its tax payments on foreign dividends were made by mistake, HM Revenue & Customs told an appeals court Thursday, urging it to overturn the ruling.
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May 15, 2025
Texan Says IRS' $1M FBAR Penalty Unconstitutional
A Texan urged a federal court to dismiss the U.S. government's suit seeking to collect $1 million in penalties for unreported offshore bank accounts, arguing that the IRS' penalty assessment violated her constitutional right to a jury trial.
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May 15, 2025
China Calls For BRICS To Limit Trade Restrictions On US
China is willing to respond to U.S. tariffs jointly with BRICS, a group of 10 governments including Brazil, Russia and India, but is urging restraint on the use of trade restrictions for now, the country's Ministry of Commerce said.
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May 15, 2025
Ex-Solicitor Hit With 1st Individual Tax Avoidance Stop Notice
HM Revenue & Customs has ordered a struck-off solicitor to stop promoting two tax avoidance schemes, the first notice of its kind issued against an individual, the tax authority said Thursday.
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May 14, 2025
Lawmakers Line Up To Unwind Trump's 'Chaotic' IEEPA Tariffs
Nearly 150 members of Congress have thrown their support behind 12 state attorneys general suing to halt the Trump administration's "emergency" tariffs, arguing they far exceed the statutory authority of a president.
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May 14, 2025
House Panel To Fold $3.8T Tax Overhaul Into Budget Package
The House Budget Committee has scheduled a vote Friday on legislation that would combine the House Ways and Means Committee's $3.8 trillion tax bill with the work of other House committees as part of the fiscal 2025 budget reconciliation bill.
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May 14, 2025
Eversheds Sutherland Rehires Tax Expert From DLA Piper
Eversheds Sutherland is welcoming back a tax expert in the U.K. who spent the last seven years at DLA Piper, the firm announced.
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May 14, 2025
EU Wrong To Deny Dutch Tax Firm's Trademark, Court Says
A Dutch consultancy was wrongly denied a trademark for "Taxmarc" in the European Union after a German consultancy that controlled a trademark for "X Taxman" opposed its registration, the European General Court said Wednesday.
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May 21, 2025
BCLP Hires 2 Partners From Taylor Wessing, A&O Shearman
Bryan Cave Leighton Paisner LLP said Wednesday that it has recruited two new partners from Allen Overy Shearman Sterling and Taylor Wessing LLP to boost its finance and tax capabilities in London.
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May 13, 2025
House Panel Clears $3.8T Extension of 2017 Tax Overhaul Law
The House Ways and Means Committee voted along party lines early Wednesday to approve a $3.8 trillion tax bill that would make permanent many of the tax cuts for businesses and individuals enacted in President Donald Trump's first term.
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May 13, 2025
UK Crime Agency's Tax Penalties Upheld In Laundering Case
The U.K.'s National Crime Agency can collect £900,000 ($1.2 million) in tax and penalty assessments from a married couple on income the agency claims they gained through money laundering without proving there was an actual tax loss, the Upper Tribunal ruled.
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May 13, 2025
CarMax Says SC Failed To Justify Apportionment Change
South Carolina's tax agency did not prove that CarMax used intercompany transactions to distort an entity's business activity and its state tax burden, the company told an appeals court, arguing that the state was wrong to make CarMax use an alternative apportionment method.
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May 13, 2025
Trade Court Panel Looks Askance At Trump Tariff Justification
A U.S. Court of International Trade panel expressed skepticism Tuesday that the emergency law President Donald Trump is using to impose global tariffs left the determination of an "unusual and extraordinary threat" to be a political rather than legal question.
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May 13, 2025
UK E-Invoicing Adoption Calls For HMRC Effort, Group Says
If HM Revenue & Customs wants companies to broadly and voluntarily adopt e-invoicing measures, it needs to work on standardizing the software while also creating an incentive campaign, a group representing U.K. tax professionals said Tuesday.
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May 13, 2025
8th Circ. Urged To Enforce IRS Pricing Method On Medtronic
The U.S. Tax Court erred by tossing the IRS' suggested method to price royalties for intangible property licensed by medical device maker Medtronic to a Puerto Rican affiliate because its products differed from those of comparable uncontrolled companies, a government attorney told the Eighth Circuit on Tuesday.
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May 13, 2025
EU Council Agrees On Directive To Simplify VAT On Imports
The Council of the European Union said Tuesday that it reached an agreement on how to simplify value-added tax rules for selling imported goods in EU countries.
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May 12, 2025
Feds Say Tribal Tariff Dispute Must Stay In US Trade Court
The U.S. Department of Homeland Security is fighting Montana tribal members' attempt to stop the transfer of their lawsuit challenging President Donald Trump's Canada tariff orders from federal court to the U.S. Court of International Trade, saying the CIT has exclusive jurisdiction over the case.
Expert Analysis
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What's Ahead As Transparency Act Comes To A Crossroads
Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.
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7 Ways 2nd Trump Administration May Affect Partner Hiring
President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.
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E-Discovery Quarterly: Rulings On Custodian Selection
Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.
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Exploring Venue Strategy For Trump-Era Regulatory Litigation
Litigation will likely play a prominent role in shaping policy outcomes during the second Trump administration, and stakeholders have several tools at their disposal to steer regulatory litigation toward more favorable venues, say attorneys at Covington.
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An Associate's Guide To Career Development In 2025
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.
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Making The Pitch To Grow Your Company's Legal Team
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.
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Tax Court Should Update Framework For Defining Insurance
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.
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When US Privilege Law Applies To Docs Made Outside The US
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.
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Impact Of Corporate Transparency Act Ambiguity On Banks
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.
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6 Changes I Would Make If I Ran A Law School
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.
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Firms Still Have The Edge In Lateral Hiring, But Buyer Beware
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.
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Think Like A Lawyer: 1 Type Of Case Complexity Stands Out
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.
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Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity
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.