International
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February 28, 2025
Baltimore Law Firm Loses Bid To Lift IRS Account Freeze
A Maryland federal magistrate judge declined Friday to rethink her order upholding an IRS freeze on a Baltimore law firm's bank account over a $1.5 million tax debt, finding the firm failed to cite any case law that justified reconsideration.
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February 28, 2025
FinCEN Delays Corporate Transparency Act Deadlines
The Financial Crimes Enforcement Network said it will not take any enforcement actions against companies failing to file or update their beneficial ownership information reports pursuant to the Corporate Transparency Act until an interim final rule becomes effective.
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February 28, 2025
UK VAT Digital Transition Saved Cos. Up To Estimated £915M
A U.K. program mandating businesses use certain software to keep digital records and submit forms for value-added tax saved up to an estimated 49 million collective hours in the 2022-23 tax year, which HM Revenue & Customs valued as worth up to £915 million ($1.2 billion).
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February 28, 2025
UN Tax Pact Best Bet For Certainty, Sovereignty, Report Says
The United Nations' global tax convention is the most viable opportunity — politically and economically — for governments outside the U.S. to provide tax certainty, prized by multinational corporations, and protect their tax sovereignty under an American administration threatening those realms, the Tax Justice Network said.
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February 28, 2025
China Signals Retaliation Following Extra 10% US Tariff
The Chinese government said Friday it will pursue additional "countermeasures" if President Donald Trump's administration follows through on plans to impose an extra 10% tariff on Chinese goods.
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February 28, 2025
Taxation With Representation: Gibson Dunn, Skadden
In this week's Taxation With Representation, Blackstone acquires Safe Harbor Marinas, National Grid sells its green subsidiary in the U.S. to Brookfield, Apollo Global Management buys Bridge Investment Group Holdings Inc., and Teleflex splits into two publicly traded companies.
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February 28, 2025
Indian Beats Tax Fraud Extradition On Prison Extortion Fears
Sanjay Bhandari will not be extradited to India to face charges of tax evasion and money laundering as a London court ruled Friday that he would be at "a real risk" of inhumane treatment in one of the largest prisons in the world.
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February 27, 2025
EU Prepared To Retaliate Against US Over Tariffs, Officials Say
European Union officials said Thursday that the bloc is prepared to retaliate against the U.S. if President Donald Trump follows through with tariffs on over $600 billion of goods, a situation that two law professors said risks becoming a trade war more than past disputes.
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February 27, 2025
Progress Continues On Amount B, OECD Head Tells G20
The Organization for Economic Cooperation and Development's work toward a global transfer pricing agreement known as Amount B has made "significant strides" despite the remaining obstacles, OECD Secretary-General Mathias Cormann told Group of 20 finance ministers and central bank governors Thursday.
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February 27, 2025
EU Floats Simplifications To Climate Measures To Save €6B
The European Commission has proposed a set of measures aimed at simplifying the European Union's carbon border adjustment mechanism and other climate provisions to save €6.3 billion ($6.6 billion) in administrative costs and spur €50 billion in additional investments.
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February 27, 2025
UK Seeks Input On Plan To Cut Inheritance Tax Farm Relief
HM Revenue & Customs on Thursday asked for public comments on inheritance tax changes that would cut tax relief available to owners of farmland.
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February 27, 2025
Poland Can't Exclude Domestic Funds From Tax Break
The Polish government can't offer corporate tax exemptions to investment funds managed outside the country unless it offers the same benefits to domestically managed funds, the European Court of Justice ruled Thursday.
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February 27, 2025
10 EU Countries Working To Create Tax Dispute Committee
A group of 10 European Union member countries are working on a multilateral agreement that would establish a permanent committee to settle tax disputes through arbitration, Austria's finance ministry said Thursday.
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February 27, 2025
Trader Defends Legitimacy Of £1.4B Tax Refunds In Fraud Trial
British trader Sanjay Shah and others accused by Denmark's tax authority of involvement in a fraudulent trading scheme to procure billions in tax refunds argued in a London court Thursday that they could not have fraudulently applied for the refunds because they believed the trades were legitimate.
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February 26, 2025
Police Supply Store, Others Ask 5th Circ. To Keep CTA Paused
A Texas police supply store joined with Mississippi libertarians and several other parties asking the Fifth Circuit to keep the Corporate Transparency Act on hold, saying ending the stoppage of that law could force 32 million business entities to file beneficial ownership reports.
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February 26, 2025
IRS Spinoff Safe Harbors Not Seen As All-Purpose Reprieve
Safe harbors proposed by the IRS would allow certain corporate spinoffs to get statutory tax-free treatment, but the bright-line requirements to qualify for these provisions reflect the tension between a blanket approach and the unique complexities of each transaction.
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February 26, 2025
Capital Gains Tax Breaks Lack Proof Of Growth, OECD Says
There is little to no empirical evidence to support the position adopted across most OECD governments that tax relief for capital gains leads to stronger economic growth, broader entrepreneurship and higher savings, the organization said in a report published Wednesday.
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February 26, 2025
Billionaire Claims HMRC Failed To Hold Lawful Tax Inquiry
HM Revenue & Customs failed to lawfully notify the right people in its investigation of tax returns for two partnerships, counsel for a hedge fund billionaire told a London court Wednesday.
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February 26, 2025
ATO Moving Fast Against Outlier Tax Debtors, Chief Says
The Australian Taxation Office is "moving harder and faster" to collect from the 1% of tax debtors who owe about a fifth of the country's roughly AU$50 billion ($31.5 billion) in tax debts, according to prepared remarks by the country's tax commissioner for lawmakers Wednesday.
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February 26, 2025
Coke's $2.7B Tax Bill Due To 'Bait And Switch,' 11th Circ. Told
Coca-Cola urged the Eleventh Circuit to reverse a U.S. Tax Court decision putting the beverage giant on the hook for $2.7 billion in taxes, arguing the ruling excused the IRS' "blatant bait and switch" regarding how it allocates income from foreign affiliates.
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February 26, 2025
Tax Overhaul Designer Named Top Tax Adviser To Treasury
An attorney who worked for Exxon Mobil and helped design the 2017 tax overhaul in President Donald Trump's first term has been appointed to serve as a top tax adviser to Treasury Secretary Scott Bessent, Treasury announced Wednesday.
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February 25, 2025
Promised German Tax Cuts Could Come As Deficit Climbs
With the Christian Democrats, winners of Germany's election, having promised to pursue tax cuts, the country's Ministry of Finance revealed Tuesday that the budget deficit reached €18.7 billion ($19.7 billion) last month.
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February 25, 2025
Canada Seeking Feedback On EV Supply Chain Tax Credit
Canada's government is looking for public input on a plan to introduce a tax credit designed to help support the expansion of electric vehicle manufacturing.
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February 25, 2025
Brazil Starts Corp. Tax Compliance Benefit Program
Companies in Brazil that are up to date and compliant with their tax obligations will be offered benefits for doing so as part of a pilot program, the country's tax service said.
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February 24, 2025
Eaton's Foreign Tax Credits Rejected By Tax Court
The U.S. Tax Court rejected foreign tax credits that Eaton Corp. had claimed on its lower-tier overseas entities' income taxes for 2007 and 2008, saying in a Monday opinion that its overseas ownership structure had disqualified the multinational power management company.
Expert Analysis
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.
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Using A Children's Book Approach In Firm Marketing Content
From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.
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New Crypto Reporting Will Require Rigorous Recordkeeping
The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.
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Exploring An Alternative Model Of Litigation Finance
A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.
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A Vision For Economic Clerkships In The Legal System
As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.