International
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June 02, 2025
Halliburton Wants IRS To Release Docs In $35M Tax Dispute
The Internal Revenue Service should be ordered to comply with Halliburton's discovery requests in a dispute over a $35 million deduction for payments the company said it made to a foreign government to protect its employees from harassment, the company told a Texas federal court.
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June 02, 2025
GOP Budget Adds Punitive Twist To Talks On Digital Taxes
The House-passed budget's punitive tax hikes on companies and people from countries with digital services taxes is poised to complicate trade negotiations aimed at removing DSTs and to weaken foreign investment in the U.S., fiscal experts told Law360.
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June 02, 2025
Remote Workers Take German Tax Case To EU's Top Court
The European Court of Justice said Monday it will hear the case of two taxpayers against a German regional tax authority over whether Swiss residents working remotely are taxable in Germany.
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June 02, 2025
CJEU Set To Hear SocGen's Case In Swedish Tax Dispute
The Court of Justice of the European Union said Monday that it will hear the case of French banking giant Société Générale SA against the Swedish tax authority over the taxation of nonresident companies under the European treaty.
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June 02, 2025
OECD Releases Consolidated Text Of Data-Swap Guidance
The Organization for Economic Cooperation and Development published consolidated text of a global reporting standard Monday to help tax administrations exchange financial information about individuals who may be trying to hide money from their tax authorities at home.
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June 02, 2025
IRS To Hold Hearing On Sourcing Cloud Transaction Income
The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.
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May 30, 2025
US-China Trade Talks Could Resume After Stall Over Minerals
Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.
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May 30, 2025
Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight
An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.
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May 30, 2025
HMRC Correctly Handled Land Tax Dodge, UK Court Says
HM Revenue & Customs followed the correct procedures to collect taxes on six individuals who attempted to dodge the U.K.'s land tax by transacting with a special purpose vehicle in Guernsey, the Upper Tribunal ruled.
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May 30, 2025
Isle Of Man Agrees To Work With UK Against Tax Avoidance
Isle of Man authorities reached an agreement with the U.K. government to work together in a crackdown on promoters of tax avoidance schemes, according to a joint statement.
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May 30, 2025
UK Midsize Biz Owners Wary Of Risk Exposure, Report Says
Owners and operators of midsize U.K. businesses are just as wary of risk exposure in personal taxes as they are in business taxes except under certain circumstances, according to a report commissioned by HM Revenue & Customs.
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May 30, 2025
Taxation With Representation: Kirkland, Cravath, Latham
In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.
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May 29, 2025
DC Court Blocks Trump's Tariffs As Overreach Of Power
The International Emergency Economic Powers Act does not empower the president to impose tariffs, the D.C. federal district court said Thursday, ruling that President Donald Trump's global levies are unlawful and barring his administration from enforcing them on two toymakers who challenged the policies.
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May 29, 2025
Fed. Circ. Revives Trump Tariffs As It Weighs Appeal
The Federal Circuit temporarily reinstated President Donald Trump's global tariffs Thursday, a day after the U.S. Court of International Trade held that an emergency law did not give the president "unbounded authority" to impose the measures.
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May 29, 2025
Australia Outlines Compliance For Thin Capitalization Test
The Australian Taxation Office is looking for feedback on draft compliance guidance for corporations looking to use one of its new thin capitalization tests as they relate to cross-border financing arrangements, it said Thursday.
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May 29, 2025
£2.4B Employment Tax Credit Has Limited Value, Report Says
A U.K. employment tax credit worth around £2.4 billion ($3.2 billion) a year in payroll tax relief for businesses has limited value, according to a report commissioned by HM Revenue & Customs, with the smallest businesses reaping the most benefit.
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May 29, 2025
Biz Group Calls On EU To Resolve Pillar 2 Dispute With US
The European Union should work quickly to resolve problems with the Pillar Two global minimum corporate tax and its interaction with the U.S. tax system, the American Chamber of Commerce for the EU said.
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May 29, 2025
IRS Annual Gross Collections Top $5 Trillion For First Time
The Internal Revenue Service collected $5.1 trillion in gross revenue in fiscal year 2024, a 9% increase over last year's $4.7 trillion total, marking the first time the tax haul has been above $5 trillion, the agency said Thursday.
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May 29, 2025
US Tariffs Spark Profit Warnings For UK Pension Sponsors
British businesses might seek to tap into pension surpluses because of ongoing financial losses caused by U.S. tariffs, a professional services firm has warned.
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May 28, 2025
International Trade Court Strikes Down Trump's Tariffs
The International Emergency Economic Powers Act does not give the president the "unbounded authority" to impose tariffs on goods from nearly every country in the world, the U.S. Court of International Trade ruled Wednesday, handing a win to small businesses and states challenging some of President Donald Trump's steep tariffs.
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May 28, 2025
Fintech Group Warns Remittance Tax Will Hurt Consumers
The American Fintech Council sent a letter to members of Congress asking them to reconsider a proposed tax on remittances that is a part of the $3.8 trillion bill to extend and make permanent the Republican Party's 2017 tax overhaul law, also known as The One Big Beautiful Bill Act.
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May 28, 2025
4 Big Questions Raised By International Retaliatory Tax In GOP Bill
Republicans' evolving international retaliatory tax proposal has been viewed as an effort to influence foreign tax regimes and as a possible tool in global tax and trade talks, but it has sparked concerns that it could escalate a trade war or otherwise hurt the U.S. economy. Here, Law360 explores four questions raised by the proposal.
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May 28, 2025
$3.9 Trillion Price Tag On House Budget Bill's Tax Provisions
Tax provisions included in the House-passed budget reconciliation bill that would extend and make permanent many provisions in the 2017 tax overhaul would cost $3.9 trillion over the next decade, according to a report released Wednesday by the Joint Committee on Taxation.
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May 28, 2025
Mexico Collected $982M From Transfer Pricing Last Year
Mexico's transfer pricing regime collected 19 billion pesos ($980 million) from large businesses last year, part of a trend that has seen the country's transfer pricing revenue more than triple over the past five years compared with the prior five-year period, its tax administration said.
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May 28, 2025
One Convicted For Role In €195M VAT Fraud Scheme
A Munich court convicted a man for his role in a value-added tax fraud scheme that spanned 17 countries and caused an estimated €195 million ($220 million) in damages, the European Public Prosecutor's Office said Wednesday.
Expert Analysis
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Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?
A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.
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3 Leadership Practices For A More Supportive Firm Culture
Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.
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E-Discovery Quarterly: Rulings On Hyperlinked Documents
Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.
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Loper Bright Limits Federal Agencies' Ability To Alter Course
The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.
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After Chevron: Delegation Of Authority And Tax Regulators
The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.
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Lawyers Can Take Action To Honor The Voting Rights Act
As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.
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How To Grow Marketing, Biz Dev Teams In A Tight Market
Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.
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Rock Climbing Makes Me A Better Lawyer
Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.
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Contract Disputes Recap: Preserving Payment Rights
Stephanie Magnell and Zachary Jacobson at Seyfarth examine three recent decisions that together illustrate the importance of keeping accurate records and adhering to contractual procedures to avoid inadvertently waiving contractual rights to cost reimbursements or nonroutine payments.
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Think Like A Lawyer: Dance The Legal Standard Two-Step
From rookie brief writers to Chief Justice John Roberts, lawyers should master the legal standard two-step — framing the governing standard at the outset, and clarifying why they meet that standard — which has benefits for both the drafter and reader, says Luke Andrews at Poole Huffman.
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Lead Like 'Ted Lasso' By Embracing Cognitive Diversity
The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.
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Now More Than Ever, Lawyers Must Exhibit Professionalism
As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.
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Reading Between The Lines Of Justices' Moore Ruling
The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.