International

  • 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.

  • 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.

  • 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.

  • 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.

  • March 18, 2025

    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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • Replacing The Stigma Of Menopause With Law Firm Support

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    A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.

  • Planning Law Firm Content Calendars: What, When, Where

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    During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

  • It's Time For A BigLaw Associates' Union

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    As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.

  • How Justices Upended The Administrative Procedure Act

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    In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.

  • Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster

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    Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.

  • Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?

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    A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.

  • 3 Leadership Practices For A More Supportive Firm Culture

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    Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.

  • E-Discovery Quarterly: Rulings On Hyperlinked Documents

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    Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.

  • Loper Bright Limits Federal Agencies' Ability To Alter Course

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    The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.

  • After Chevron: Delegation Of Authority And Tax Regulators

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    The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.

  • Lawyers Can Take Action To Honor The Voting Rights Act

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    As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.

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