International
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October 03, 2025
Taxation With Representation: Kirkland, Paul Weiss, Cravath
In this week's Taxation With Representation, video game maker Electronic Arts agrees to be acquired by the Saudi Arabia Public Investment Fund, Silver Lake and Affinity Partners; online mortgage giant Rocket closes its acquisition of rival Mr. Cooper Group; and Berkshire Hathaway acquires international energy company Occidental's chemical business.
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October 03, 2025
Denmark's £1.4B Cum-Ex Loss Raises Legal Strategy Doubts
Denmark's "bruising" defeat in its £1.4 billion ($1.9 billion) cum-ex fraud case against trader Sanjay Shah and others calls into question its legal strategy and the scope of its claim, lawyers have said, although they believe an appeal appears inevitable.
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October 03, 2025
Denmark Denied Permission To Appeal £1.4B Cum-Ex Defeat
Denmark cannot revive its £1.4 billion ($1.9 billion) against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.
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October 02, 2025
IRS Data-Sharing Case Won't Be Paused For Gov't Shutdown
The U.S. Department of Justice must still submit court-ordered information in a lawsuit challenging the Internal Revenue Service's sharing of tax data with immigration authorities by Oct. 24, a D.C. federal judge ruled, despite the federal government shutdown that began Wednesday.
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October 02, 2025
German States Push To Halt Min. Tax As US Seeks Exemption
Three German states said they would ask the country's other states Thursday to push the federal government to suspend the 15% global minimum tax in Germany while the U.S. proposal to exempt American companies from most of the system is being resolved.
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October 02, 2025
Debt Recovery Actions Not Taxable Under EU Law, ECJ Says
A holding company pursuing debt recovery is not providing a taxable service to its debtor under European value-added tax law, the European Union's top court ruled Thursday.
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October 02, 2025
Tax KC Sued By Hedge Fund Billionaire Over Negligence
Billionaire Michael Platt and his hedge fund BlueCrest Capital Management have sued a senior One Essex Court barrister who represented them in a dispute with the U.K. tax authority over the identity of awards paid under a special partnership program.
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October 02, 2025
Denmark Loses £1.4B Cum-Ex Fraud Case Against UK Trader
Denmark lost on Thursday its £1.4 billion ($1.9 billion) legal claim against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.
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October 01, 2025
Calif. Importer, Son Both Get Prison For $8M Customs Fraud
A California federal judge sentenced a Los Angeles Fashion District business owner and his son to more than eight years and seven years in prison, respectively, after they were found guilty of ducking more than $8 million in customs duties and failing to report over $17 million in cash transactions on tax returns.
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October 01, 2025
EU Wants To Lead Bloc On UN Tax Treaty's Dispute Section
The European Union's executive branch has asked the bloc's member states to grant it the final say in agreeing to a legally binding protocol on dispute resolution within the United Nations' framework convention on international tax cooperation, saying the matter falls within its responsibilities.
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October 01, 2025
States, Businesses Push Justices To Extend Tariff Arguments
The dozen states, several small businesses and Illinois toymakers that challenged President Donald Trump's emergency tariffs filed a joint motion Wednesday requesting more time to better represent their different claims for oral arguments at the U.S. Supreme Court in November.
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October 01, 2025
NJ Can't Tax Sale Of Stake In Foreign Co., Enterprise Says
Car rental giant Enterprise asked the New Jersey Tax Court to negate a $1.2 million tax assessment stemming from a sale of interest in an Israel-based software company, arguing that the gain was nonoperational income that should be allocated to Enterprise's home state, Missouri, for tax purposes.
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October 01, 2025
Healthcare Training Co. Says Firm's VAT Advice Cost It £2M
An accounting firm gave incorrect advice to a healthcare worker training company on value-added tax registration, the company alleged in a claim filed with a London court, leading to a tax liability of almost £2 million ($2.7 million).
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October 01, 2025
Peru Says Mining Co. Can't Revive $417M Penalty Claim
Peru is resisting an Arizona-based mining company's bid to annul a decision by international arbiters who found they lacked jurisdiction over $417 million in penalties and interest the country imposed for unpaid royalties, saying the company is wrong to claim the issue was improperly ignored.
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October 01, 2025
Caplin & Drysdale Adds Longtime IRS Pro To DC Office
Caplin & Drysdale has grown its Washington, D.C., office with the addition of a veteran Internal Revenue Service attorney, the firm announced Wednesday.
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October 01, 2025
8th Circ. Reverses IRS Win In 3M Transfer Pricing Case
The Eighth Circuit reversed a U.S. Tax Court ruling Wednesday that backed the Internal Revenue Service's decision to reallocate nearly $24 million of 3M Co.'s Brazilian income, holding that the transfer pricing regulations underlying the adjustment are invalid.
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October 01, 2025
Bank CEO Cleared Of Dishonestly Assisting £415M Tax Fraud
A Caribbean bank and its former chief executive have been cleared of dishonestly assisting a £415 million ($558 million) value-added tax fraud as a London court ruled that he did not know about the scheme to defraud tax authorities.
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September 30, 2025
IRS To Rework Corporate AMT Proposed Regs
The Internal Revenue Service plans to revise proposed regulations for the corporate alternative minimum tax, the agency announced Tuesday, including rules that would lessen businesses' compliance demands and costs tied to assessing their liability.
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September 30, 2025
Justices Could Enable IEEPA Taxes On Any Trade, Experts Say
If the U.S. Supreme Court decides that a president's power to regulate imports and exports under the International Emergency Economic Powers Act encompasses tariffs, a president could tax services, investments and intellectual property flowing into or out of the country, trade experts said Tuesday.
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September 30, 2025
IRS Further Delays Deadlines For Victims Of Israel-Hamas War
The Internal Revenue Service further postponed already-delayed tax return and payment deadlines that were set for Tuesday for those impacted by the Israel-Hamas war from 2023 through 2025, the agency said.
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September 30, 2025
IRS Penalty Case Tossed For Now Over Shifting Legal Claims
A woman's shifting legal theories doomed her challenge to IRS penalties related to her delayed disclosure of a foreign inheritance, a California federal judge found, tossing the suit but allowing her to amend her complaint.
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September 30, 2025
Altria Loses Out On $38M Refund On Foreign Subsidiaries
Tobacco products maker Altria is not entitled to a $38 million tax refund on foreign subsidiaries, a Virginia federal court found, saying the company was an indirect shareholder through its interest in Anheuser-Busch and therefore owes taxes on its portion of the subsidiaries' income.
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September 30, 2025
UK's Average R&D Tax Credit Claim Jumps 33%
The U.K. has seen the average value of research and development tax credit claims rise despite the overall number of such claims falling in the last tax year, HM Revenue & Customs said Tuesday.
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September 30, 2025
Trump Orders Lumber, Furniture Tariffs To Begin Oct. 14
In an executive order signed Monday evening, President Donald Trump outlined a series of tariff rates on imported lumber and derivative products to be imposed in two weeks.
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September 30, 2025
EU Floats Tax Incentives To Encourage Savings, Investment
The European Commission has issued a blueprint for tax incentives and other measures to help the European Union's member states encourage their residents to set up savings and investment accounts.
Expert Analysis
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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
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.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.
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8 Childhood Lessons That Can Help You Be A Better Attorney
A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.
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This Election, We Need To Talk About Court Process
In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.
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Mental Health First Aid: A Brief Primer For Attorneys
Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.
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The Trade And Tax Issues Behind US-Canada Digital Tax Clash
The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.
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Litigation Inspiration: Honoring Your Learned Profession
About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.