International
-
June 17, 2025
IRS Updates Prefiling Program For Large Biz, Int'l Taxpayers
The Internal Revenue Service has made several changes to its prefiling agreement program, including updating the guidelines to help large corporate and international taxpayers flag potential issues before submitting returns, the agency said Tuesday.
-
June 17, 2025
Swedish Tax Agency Asks For Greater Enforcement Powers
The Swedish Tax Agency is looking to enhance its ability to address tax crimes, it told the country's Ministry of Finance on Tuesday, sharing proposals that would strengthen its law enforcement powers and grant it the power to store biometric data.
-
June 17, 2025
Norway Looks To Adopt Updated Pillar 2 Guidance
The Norwegian Ministry of Finance proposed updating its adoption of the Organization for Economic Cooperation and Development's global minimum tax to integrate administrative guidance issued over the past year.
-
June 17, 2025
HMRC Challenges Tax Treatment Of Partnership Awards
HM Revenue & Customs told the U.K. Supreme Court on Tuesday that partnership awards allocated to a corporate entity and then distributed to partners should be taxed as if they were allocated to individual members.
-
June 16, 2025
US, UK Reach Trade Deal On Cars; Steel Tariffs Still Unresolved
President Donald Trump signed an order Monday enshrining the nation's new trade deal with U.K. governments under which the U.S. agreed to slash tariffs on 100,000 imported U.K. automobiles and auto parts, while eliminating tariffs on certain aerospace products but leaving steel and pharmaceuticals tariffs for future negotiations.
-
June 16, 2025
Senate Bill Sticks With TCJA's $10,000 SALT Cap
The Senate Finance Committee's tax portion of the chamber's budget reconciliation bill released Monday follows the House's lead on some provisions while breaking with the lower chamber's hard-won compromises on an increased state and local tax deduction and the phaseout of green energy credits.
-
June 16, 2025
The Tax Angle: EITC Audits, UTPR, Energy Credits
From a look at Republicans' efforts to audit the earned income tax credit, complaints about unfair foreign taxation under the OECD's Pillar Two framework and Democrats' push against Republican plans to strip the Inflation Reduction Act's energy credits from the code, here's a peek into a reporter's notebook on a few developing tax stories.
-
June 16, 2025
Book Profits Much Higher Than Taxable Income, Paper Says
Companies report about three to four times higher profits on financial statements for investors compared with the taxable income they report to authorities, a phenomenon most prevalent among multinational corporations, which suggests book profits underestimate profit shifting, the EU Tax Observatory said Monday.
-
June 16, 2025
G7 Could Raise $214B Yearly From 2% Wealth Tax, Group Says
The Group of Seven countries could raise $214 billion a year if each government imposed a 2% wealth tax on fortunes above $100 million, with the U.S. potentially raising $161 billion by itself, a group of wealthy Canadians said Monday in support of such measures.
-
June 16, 2025
Trump Eyes Trade Deal With Canada During G7 Summit Talks
President Donald Trump said at the G7 summit Monday that he would work with Canadian Prime Minister Mark Carney to reach a trade deal, raising the possibility that an agreement could be struck before the multilateral meeting concludes.
-
June 16, 2025
Wealth Taxes, End Of Profit Shifting Worth $2.6T, Group Says
World governments could raise about $2.6 trillion annually, more than enough revenue to finance most climate-related needs, if they collectively adopted low-rate wealth taxes beginning with the richest 0.5% and stopped multinational corporations from shifting profits, the Tax Justice Network said Monday.
-
June 16, 2025
HMRC Warns Umbrella Co. Employees Of Tax Risks
Employees and contractors of temporary worker agencies known as umbrella companies need to be vigilant to make sure they aren't unwittingly involving themselves in tax avoidance schemes, HM Revenue & Customs said, laying out ways to spot such avoidance issues.
-
June 16, 2025
OECD Offers Template For Tax Crime Investigation Guidance
The Organization for Economic Cooperation and Development released standards Monday for jurisdictions to use when creating manuals to guide government agencies through tax crime investigations, with the aim of creating more efficient and effective processes, it said.
-
June 16, 2025
Colombian Taxpayers Owe $34M In Foreign Exchange Debts
Nearly 290 Colombian taxpayers have accumulated roughly 142.2 billion Colombian pesos ($34.6 million) in unpaid tax debts related to their foreign exchange transactions, the country's tax authority said, offering possible reductions for their associated penalties.
-
June 13, 2025
US-China Trade Talks Resume, Draw Mixed Reviews
Despite the promise of new trade talks held this week by the U.S. and China, the long-term strategic view of many companies remains concern over the obstacles they continue to face, especially if they must diversify supply chains that heavily rely on China.
-
June 13, 2025
211K Suspicious Transaction Reports Filed In France In 2024
France's anti-money laundering unit received over 211,000 reports of suspicious financial transactions in 2024, making up the vast majority of the more than 215,000 reports received by the unit, an over 13% increase from the year prior, the country's finance ministry said Friday.
-
June 13, 2025
Israeli Businessman Found Liable For $3.2M Over FBARs
An Israeli businessman who was held in contempt of court for dodging discovery requests is liable for $3.24 million in penalties and interest for willfully failing to report his foreign bank accounts, according to a Washington federal court.
-
June 13, 2025
UK Businessman Defends Asset Transfer As Tax Strategy
A British businessman denied that he transferred a company to his son to defraud a creditor, arguing it was part of a long-term tax strategy rather than a tactic to avoid repaying £4.7 million ($6.4 million) in debt.
-
June 13, 2025
Tax Credit Sales Would Be Difficult To Insure Under House Bill
House Republicans' sweeping budget bill proposes to promptly scale back the clean energy tax incentives established by the 2022 climate law, a move that would make it difficult for tax insurers to back project development deals that want to sell their tax credits for cash.
-
June 13, 2025
Taxation With Representation: Debevoise, Latham, Paul Weiss
In this week's Taxation With Representation, Brown & Brown Inc. buys Accession Risk Management Group Inc., Allison Transmission Holdings Inc. acquires Dana Inc.'s off-highway unit, Qualcomm Inc. buys Alphawave IP, and Warner Bros. Discovery announced it will split into two publicly traded companies.
-
June 13, 2025
Private Schools Lose Bid To Overturn VAT On Fees
The U.K. government has not breached human rights law by extending value-added tax to private school fees, the High Court ruled Friday, rejecting claims brought by a group of schools and families.
-
June 12, 2025
Broader German Tax Base Key To Fiscal Growth, OECD Says
Germany should consider multiple avenues to broaden its tax base in the name of ensuring medium-term fiscal stability, the Organization for Economic Cooperation and Development recommended Thursday, saying such changes could also lead to lower labor taxation.
-
June 12, 2025
China Agrees To Loosen Rare Earth Restrictions, US Says
Chinese trade negotiators have agreed to lift export controls on rare-earth elements in exchange for the U.S. walking back a campaign to revoke visas for Chinese students, according to statements by U.S. officials, which experts said leave key issues unresolved.
-
June 12, 2025
UK Investors Sue Cricket Team Owner Over Claimed Tax Fraud
Three U.K.-based investors in an Indian Premier League cricket team are seeking £10 million ($13.6 million) in damages from the club's owner, claiming in a London court that he duped them over the tax implications of selling their shares in his business.
-
June 12, 2025
Customs Missteps Don't Void VAT Exemption, ECJ Says
A horse owner can still claim a value-added tax exemption if she was merely negligent, rather than deceitful, in failing to declare her horses with Swedish customs officials, the European Court of Justice held Thursday.
Expert Analysis
-
3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
-
IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
-
Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
-
Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
-
10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
-
Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
-
10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
-
An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
-
Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
-
E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
-
A Cold War-Era History Lesson On Due Process
The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.
-
How BigLaw Executive Orders May Affect Smaller Firms
Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.
-
Lawsuits Shouldn't Be Shadow Assets For Foreign Capital
Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.