International
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November 20, 2025
Importers Left With Uncertainty After US-China Trade Truce
U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation.
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November 20, 2025
Treasury To Curtail Tax Credits For Unauthorized Immigrants
The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday.
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November 20, 2025
EU Needs Unified Tax Benefits For Electricity, Experts Say
The European Union needs a unified approach to tax benefits that would treat electricity more favorably than fossil fuels amid an impasse surrounding its overhaul to the energy taxation system, experts told the European Parliament's tax committee Thursday.
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November 20, 2025
FBAR Penalty Against Ex-Prof Is Constitutional, Court Says
A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it.
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November 20, 2025
EU Council Approves Tax Deal Changes With 5 States
The Council of the European Union said Thursday that it has approved updates to tax agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland, including new rules to help prevent tax evasion and fraud.
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November 19, 2025
Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real
A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.
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November 19, 2025
Tax Court Upholds Rejection Of Tax Tipster's Award
The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday.
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November 19, 2025
Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty
Governments expressed widespread support for adopting measures to strengthen the mutual agreement procedure within a protocol on dispute resolution in the United Nations tax convention during the latest round of negotiations.
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November 19, 2025
Tax Court Substance Ruling Offers Silver Lining For Taxpayers
Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions.
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November 19, 2025
OECD Releases Model Tax Treaty Updates For Amount B
The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B.
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November 19, 2025
EU Tax Compliance Rules Raise €6.8B Annually, EC Finds
The European Union's directive for administrative cooperation in taxation, known as DAC, has helped tax authorities generate €6.8 billion ($7.8 billion) a year in extra revenue, the European Commission said in a report Wednesday.
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November 19, 2025
Trump's Global Tariffs Curtailed Trade, Data Shows
U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.
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November 18, 2025
Korea Wins Annulment Of $216M Lone Star Funds Award
South Korea on Tuesday prevailed in its bid to wipe out a $216 million arbitral award issued to an affiliate of Lone Star Funds, though the private equity firm has already vowed to resubmit its claim to a new tribunal.
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November 18, 2025
Malawi Reiterates Bid For Gem Export Tax Investigation
Malawi has bolstered its bid for a Washington federal judge to reconsider his decision barring the country from pursing discovery against a gemstone company that partnered with a mining outfit the country claims dodged billions of dollars in taxes and export royalties.
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November 18, 2025
French Inheritance Tax Break Grew To €5.5B, Auditor Finds
The French government's inheritance tax break for family-owned businesses needs to be overhauled as the cost surged to more than €5.5 billion ($6.4 billion) last year, the state auditor said Tuesday.
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November 18, 2025
Tax Return Preparer Gets 18 Months For $25 Million Fraud
A California tax return preparer who admitted he participated in a scheme that claimed $25 million in false refunds was sentenced to 18 months in prison by a California federal court, the U.S. Department of Justice said.
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November 18, 2025
Checklist Could Help Simplify Global Tax Policy, OECD Says
A checklist of questions for global tax policymakers could help simplify the outcomes of their work, the OECD said in a Tuesday report to the Group of 20 nations.
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November 17, 2025
Judge Questions Eaton's Role In Lowered Credit Rating
Tax Court Judge Albert Lauber questioned an expert for Eaton on Monday about how he arrived at a lowered credit rating for the U.S. company in a report he prepared in January 2013, shortly after it acquired an Irish-based global electrical products manufacturer and inverted.
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November 17, 2025
Ex-Russian Gas CFO Resentenced To 6 Years For Tax Crimes
A Florida federal judge handed a nearly six-year prison term to a Russian gas company's former chief financial officer, who was convicted for tax evasion after the Eleventh Circuit vacated a prior sentence earlier this year.
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November 17, 2025
Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free
A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International Trade's decision in a decade-old dispute.
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November 17, 2025
OMB Reviewing Treasury Regs On OECD Crypto Reporting
The Office of Management and Budget is reviewing regulations proposed by the U.S. Department of the Treasury to implement automatic exchanges of information between tax authorities regarding taxpayers' cryptocurrency holdings under the OECD's crypto-asset reporting framework.
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November 17, 2025
MVP: Sullivan & Cromwell's Isaac Wheeler
Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Tishman Speyer on its $3.5 billion refinancing of Rockefeller Center, earning him a spot as one of the 2025 Law360 Tax MVPs.
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November 17, 2025
Fed. Circ. Backs Commerce To Nix Turkish Steel Duties
The U.S. Department of Commerce's removal of countervailing duties on Turkish steel imports was properly justified by the government, and the lower trade court correctly upheld its determination despite objections by the domestic steel industry, the Federal Circuit affirmed Monday.
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November 17, 2025
AI Use Has Spiked In Tax Agencies Globally, OECD Says
The use of artificial intelligence has skyrocketed in tax administrations around the world, leading to increased efficiency but also increased risks of data quality issues, according to an Organization for Economic Cooperation and Development report released Monday.
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November 17, 2025
Belgium Postpones Global Minimum Tax Filing Deadline
Belgium will extend the deadline for multinational companies to file their returns as part of the 15% global minimum corporate tax regime until June 2026, the finance ministry announced Monday.
Expert Analysis
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Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
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E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
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A Cold War-Era History Lesson On Due Process
The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.
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How BigLaw Executive Orders May Affect Smaller Firms
Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.
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Lawsuits Shouldn't Be Shadow Assets For Foreign Capital
Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.
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How To Accelerate Your Post-Attorney Career Transition
Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.
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Tariffs And FCA Create Perfect Storm For Importers
The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.
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US Reassessment Of OECD Tax Deal Is Right Move
The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.
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Measuring And Mitigating Harm From Discriminatory Taxes
In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.
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Adapting To Private Practice: From DOJ Leadership To BigLaw
The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.