International

  • 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. 

  • 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.

  • 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.

  • March 17, 2025

    Coloradan Owes FBAR Penalty After Failing To Appear

    An elderly Colorado man who failed to respond to the government's claim that he owed $482,000 for failing to report his foreign bank accounts is on the hook for the bill, a federal court ruled.

  • March 17, 2025

    OECD Report Highlights Slow Growth Due To Tariff Impact

    The Organization for Economic Cooperation and Development warned Monday that the tariffs between the U.S. and Canada and those between the U.S. and Mexico risk undermining growth at a time when tax revenue is much needed to bring down debt.

  • March 14, 2025

    Whistleblower Hasn't Proved Retaliation In Tariff Fraud Case

    A former employee of two defunct footwear companies has not shown her boss fired her for confronting him about a scheme she alleged he ran to lower tariffs on certain shoes, a New York federal court ruled, letting her claim that he ran the scheme continue to trial.

  • March 14, 2025

    NZ Planning New Method Of Taxing Foreign Investment Funds

    New Zealand is proposing a new method for determining taxable income for purposes of taxing investments of 10% or less in foreign companies by certain migrants in hopes of mitigating issues that were discouraging people from moving to the country, its tax agency said Friday.

  • March 14, 2025

    Judge Splits $79M Judgment In Danish Tax Fraud Case

    A New York federal judge divided a nearly $79 million judgment against four investors and their pension plans after a jury in February found them liable for participating in a tax fraud scheme against the Danish government.  

  • March 14, 2025

    Ex-Greenberg Traurig Atty Ordered To Pay $15.5M To IRS

    A former Greenberg Traurig LLP attorney who was sentenced to prison for helping a musician skirt taxes owes $15.5 million in restitution to the Internal Revenue Service, a New York federal judge ruled.

  • March 14, 2025

    Taxation With Representation: Davis Polk, Paul Weiss

    In this week's Taxation With Representation, Mallinckrodt PLC and Endo Inc. combine, Rocket Cos. buys Redfin, and Endo divests its international pharmaceuticals business to Knight Therapeutics Inc.

  • March 14, 2025

    Struck-Off Lawyer Can't Lift Ban After Misleading HMRC

    A former consultant solicitor who misled HM Revenue and Customs to get a refund on stamp duty land tax has failed to have his professional ban lifted as a London court ruled on Friday that the sanction was fair and justified.

  • March 13, 2025

    Texan Calls $1.7M In FBAR Penalties Unconstitutional

    Constitutional law bars the United States from imposing $1.7 million in penalties for failure to report foreign bank accounts, a Texan said in urging a federal court to dismiss such an assessment against her.

  • March 13, 2025

    Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told

    The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.

  • March 13, 2025

    Australia Clarifying Managed Investment Trust Tax Regime

    The Australian government is planning to update its income tax laws to make it clear that trusts ultimately owned by a foreign pension fund can use certain concessional withholding tax rates on eligible distributions to members, the country's assistant treasurer said Thursday. 

  • March 13, 2025

    Belgian Firm Can Nix Dividends From Tax Base, Court Rules

    A Belgian engineering company was entitled to reduce its tax base by excluding dividends from its subsidiaries in member states before taxation, as per EU law and contrary to Belgian law, the Court of Justice of the European Union said in a preliminary ruling Thursday.

  • March 13, 2025

    Former IRS Counsel Joins Hinshaw In Chicago

    Hinshaw & Culbertson LLP announced that a longtime government attorney who most recently served as deputy managing counsel of the Internal Revenue Service Office of Chief Counsel in Chicago, has joined the firm's government practice as a partner.

  • March 13, 2025

    Akin's Energy Transition Group Grows With V&E Tax Atty

    Akin Gump Strauss Hauer & Feld LLP has hired a Vinson & Elkins LLP tax counsel who has spent the past decade counseling clients on the federal income tax aspects of energy transition transactions, the firm announced Thursday.

  • March 13, 2025

    5th Circ. Asks If Enforcement Delay Affects CTA Challenge

    The Fifth Circuit has asked for supplemental briefing in a challenge against the Corporate Transparency Act, asking whether the case is affected by the U.S. Treasury Department's recent decision to suspend enforcement of reporting rules for domestic companies.

  • March 13, 2025

    Trump's EU Threat May Aim To Boost Negotiation Leverage

    President Donald Trump continued his trade tactics Thursday, threatening a 200% tariff on European alcohol imports that is almost certain to be another tool to leverage in future negotiations despite the economic uncertainty it creates.

  • March 13, 2025

    Funding Deficiency May Hinder UN Tax Talks, Group Says

    Governments interested in pursuing a United Nations tax convention should step up funding for the organization, which is facing a budget shortfall, according to the Tax Justice Network, as U.S. arrears drag on quicker-than-usual funding from other countries.

  • March 13, 2025

    Insurance Brokers Could Get Tax Refunds After Court Ruling

    U.K. insurance brokers could be in line for tax refunds from the state worth up to £400 million ($518 million) after a landmark court case, according to accountancy MHA.

  • March 13, 2025

    Wait To File Taxes If You Have Capital Gains, Canada Says

    The Canada Revenue Agency recommended that taxpayers with capital gains wait to file their tax returns as it finalizes updates to its system to account for the delayed proposed increase in the inclusion rate, saying it will waive late-filing penalties.

  • March 12, 2025

    OECD Calls On Costa Rica To Limit Regressive Exemptions

    Costa Rica's tax revenue makes up just 25% of the country's gross domestic product, thanks in part to regressive exemptions to value-added and personal income taxes and its overall narrow tax bases, the Organization for Economic Cooperation and Development said.

  • March 12, 2025

    Judge Tosses Tax Fraud Claim In Mariana Bribery Case

    A federal court dismissed Wednesday a claim connected to allegations of tax fraud in a $310,000 civil asset forfeiture case brought by the U.S. government against a Northern Mariana Islands business after concluding the court lacked jurisdiction.

  • March 12, 2025

    Starbucks' Sourcing Aided $1.3B Low-Tax Profits, Report Says

    Starbucks leveraged its private certification program for coffee growers to boost profits transferred almost tax-free from Switzerland to the Netherlands to the U.K., amounting to an estimated $1.3 billion between 2011 and 2021, according to a report from a union-funded nonprofit organization.

Expert Analysis

  • Reading The Tea Leaves On Mexico, Canada And China Tariffs

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    It's still unclear whether the delay in the imposition of U.S. tariffs on Canadian and Mexican imports will result in negotiated resolutions or a full-on trade war, but the outcome may hinge on continuing negotiations and the Trump administration's possible plans for tariff revenues, say attorneys at Eversheds Sutherland.

  • How Design Thinking Can Help Lawyers Find Purpose In Work

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    Lawyers everywhere are feeling overwhelmed amid mass government layoffs, increasing political instability and a justice system stretched to its limits — but a design-thinking framework can help attorneys navigate this uncertainty and find meaning in their work, say law professors at the University of Michigan.

  • The Pros And Cons Of A 2nd Trump Term For UK Tech Sector

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    While U.S. President Donald Trump’s protectionist stance on trade could disrupt global supply chains on which many U.K. tech firms are reliant, anticipated deregulation could provide fertile ground for investment and growth, and the U.K. tech sector is bracing for a mix of opportunities, say lawyers at Shoosmiths.

  • Corp. Transparency Act's Future Under Treasury's Bessent

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    The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.

  • A Look At A Possible Corporate Transparency Act Exemption

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    Attorneys at Kirkland offer a deep dive into the application of the Corporate Transparency Act's reporting requirements specifically to U.S.-domiciled co-issuers in typical collateralized loan obligation transactions, and consider whether such issuers may be able to assert an exemption from the CTA's reporting requirements.

  • Inconsistent Injury-In-Fact Rules Hinder Federal Practice

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    A recent Third Circuit decision, contradicting a previous ruling about whether consumers of contaminated products have suffered an injury in fact, illustrates the deep confusion this U.S. Supreme Court standard creates among federal judges and practitioners, who deserve a simpler method of determining which cases have federal standing, says Eric Dwoskin at Dwoskin Wasdin.

  • In-House Counsel Pointers For Preserving Atty-Client Privilege

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    Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.

  • Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example

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    Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.

  • Accountant-Owned Law Firms Could Blur Ethical Lines

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    KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.

  • AI Will Soon Transform The E-Discovery Industrial Complex

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    Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.

  • Unpacking The Legal Foundation Of Trump's New Trade War

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    President Donald Trump's recent executive orders and proclamations regarding emergencies at the U.S. border are based on statutory powers enabling a president to address extraordinary external threats — and could be used to fend off legal challenges to the tariffs levied on Mexican and Canadian goods, says Chris Zona at Mandelbaum Barrett.

  • When Innovation Overwhelms The Rule Of Law

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    In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.

  • Imagine The Possibilities Of Openly Autistic Lawyering

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    Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.

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