International
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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
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
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
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.
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March 17, 2025
2% Tax On Ultra-Wealthy Would Raise €67B, Group Says
The implementation of a 2% minimum wealth tax in the European Union on those with over €100 million ($109 million) in assets would generate €67 billion annually while minimizing regressivity in the bloc's tax system, a think tank said.
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March 17, 2025
UK Court Affirms £300K Tax Bill For Ex-Soccer Star's TV Gig
The First-tier Tribunal was correct to find that Sky UK Ltd. employed Phil Thompson, the former captain of the Liverpool Football Club, for television appearances through his intermediary company that is liable for nearly £300,000 ($390,000) in income tax and national insurance contributions, the Upper Tribunal said Monday.
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March 17, 2025
10th Circ. Grapples With Liberty Global's $248M Tax Credit Bid
A Tenth Circuit panel questioned Monday whether Liberty Global is entitled to $248 million in foreign tax credits for the sale of a Japanese affiliate, or if legislation limits the telecommunications giant from classifying the gains as overseas income.
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March 17, 2025
Kleinberg Kaplan Adds Simpson Thacher Atty As Tax Partner
Kleinberg Kaplan announced Monday that it has added a Simpson Thacher & Bartlett LLP attorney to help provide clients with expertise on tax aspects of private investment fund formation and operation, as well as mergers and acquisitions, joint ventures and financings.
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.
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.
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.
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.
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.
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.
Featured Stories
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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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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.
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Tariff Shifts Creating Compliance Chaos For Energy Cos.
The unpredictability of President Donald Trump's tariff maneuvers is challenging energy companies' ability to comply with fluctuating mandates and making tariff violations more likely.
Expert Analysis
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Firms Must Speak Up After Trump Orders: An Associate's View
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Rachel Cohen at Skadden discusses why she is helping to organize a movement of BigLaw associates urging their firms to stand up for the rule of law after the Trump administration’s moves against Covington, Perkins Coie and Paul Weiss.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
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As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.
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What's Next For Russia Sanctions After Task Force Disbanded
Attorney General Pam Bondi’s recent disbanding of Task Force KleptoCapture, which was initially aimed at seizing Russian oligarchs’ funds and assets, is unlikely to mean the end of Russia sanctions enforcement and other economic countermeasures, as the architecture for criminal enforcement remains in place, say attorneys at BakerHostetler.
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How Law Firms Can Counteract The Loneliness Epidemic
The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.
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5 Keys To Building Stronger Attorney-Client Relationships
Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.
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Attorneys Must Act Now To Protect Judicial Independence
Given the Trump administration's recent moves threatening the independence of the judiciary, including efforts to impeach judges who ruled against executive actions, lawyers must protect the rule of law and resist attempts to dilute the judicial branch’s authority, says attorney Bhavleen Sabharwal.
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Rethinking 'No Comment' For Clients Facing Public Crises
“No comment” is no longer a cost-free or even a viable public communications strategy for companies in crisis, and counsel must tailor their guidance based on a variety of competing factors to help clients emerge successfully, says Robert Bowers at Moore & Van Allen.