International

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • February 24, 2025

    Investor Settles In $2.1B Danish Tax Fraud Case

    A U.S. investor who was among those accused by Denmark's tax agency of participating in a $2.1 billion tax fraud scheme related to fraudulently claiming refunds on tax withheld from stock dividends has reached a settlement, according to New York federal court documents filed Monday.

  • February 24, 2025

    Denmark Argues Misrepresentation Led To £1.4B Tax Refunds

    Denmark's tax authority told the High Court of Justice on Monday that it would not have paid out billions in refunds to a British trader and others accused of involvement in a fraudulent trading scheme had they not submitted forms purporting to show eligibility for tax refunds.

  • February 24, 2025

    Ex-Goldman Exec Owes For Not Filing FBARs, US Says

    A former Goldman Sachs banking executive who lives in Australia owes penalties to the Internal Revenue Service for failing to report foreign bank accounts she held, the U.S. government told a D.C. federal court.

  • February 24, 2025

    NZ Reviewing Charity Business Income Tax Exemption

    New Zealand is looking for comments on its internationally unique tax structure that allows charities and not-for-profits to conduct business activities tax-free in order to raise money, asking stakeholders whether such a regime continues to be effective, the country's tax agency said Monday.

  • February 24, 2025

    Apple To Invest $500B In US Over 4 Years As Tariffs Mount

    Apple said Monday that it would invest $500 billion in the U.S. over the next four years, weeks after President Donald Trump placed a 10% tariff on goods from China, where the company sources components for its products, and threatened tariffs on semiconductors.

  • February 24, 2025

    Aussie Tax Office Agrees To Step Up Safeguards For AI

    The Australian Taxation Office said Monday that it will implement seven recommendations made by a national auditing body regarding the agency's adoption of artificial intelligence tools, including looking closer at potential data ethics risks and the overall development of the programs.

  • February 24, 2025

    High Court Won't Hear Tax Tipster's $690M Award Claim

    The U.S. Supreme Court declined on Monday to review a man's claim for a $690 million whistleblower award for undercover recordings and tips he gave the IRS that he said led to the arrests of Swiss bankers and the success of an offshore tax disclosure program.

  • February 24, 2025

    OECD Issues Consolidated Guidance On Amount B

    The OECD issued consolidated guidance Monday that it put out throughout last year for an internationally agreed-upon method to apply the arm's-length principle to pricing baseline marketing and distribution activities by multinational corporations, known as Amount B of Pillar One.

  • February 21, 2025

    Trump Says Tariffs Coming For Countries With DSTs

    President Donald Trump's administration will impose tariffs on countries with taxes that disproportionately affect American companies, such as digital services taxes, which mainly apply to tech giants, according to a memorandum released late Friday.

  • February 21, 2025

    The Tax Angle: ABA Midyear Tax Meeting

    With a lack of government officials attending the American Bar Association's midyear tax meeting, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • February 21, 2025

    China Says Tax Deferral Boosted Foreign Reinvestment

    A tax regime exempting foreign investors from withholding taxes on certain profits generated by their China-based businesses as long as those profits are directly reinvested in projects in China led to a 15% year-over-year increase in foreign reinvestment, the country's tax administration said Friday.

Expert Analysis

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    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.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.

  • Judicial Independence Is Imperative This Election Year

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    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

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