International
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November 05, 2025
Justices Skeptical About Trump's Emergency Tariff Authority
Several U.S. Supreme Court justices asked the government to defend why well-established judicial doctrines shouldn't limit President Donald Trump's tariffs imposed under the International Emergency Economic Powers Act during oral arguments Wednesday, casting doubt on whether they believe the law provides that kind of authority.
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November 05, 2025
Poland Publishes Draft Of Global Pillar 2 Information Return
Poland's Ministry of Finance on Wednesday published a draft of legislation to implement a first-of-its-kind global information return that countries will use to carry out an international 15% minimum corporate tax agreement known as Pillar Two.
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November 05, 2025
Switzerland Adopts Tax Treaty With Zimbabwe
Switzerland has adopted the dispatch on the double taxation agreement with Zimbabwe as part of expanding its tax treaty network in the region, the Swiss government announced Wednesday.
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November 04, 2025
Malawi Asks Judge To Undo Halt Of Gem Export Tax Probe
Malawi asked a Washington federal judge to reconsider his recent decision to bar the country from pursuing discovery against a gemstone company that it alleges partnered with a mining outfit to dodge billions of dollars in taxes and export royalties.
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November 04, 2025
Former Eaton CFO Says Bond Investors Needed Reassurance
Eaton Corp.'s former chief financial officer chronicled on Tuesday the company's efforts to finance its 2012 acquisition of Ireland-based Cooper Industries, describing an atmosphere of leery bond investors after the Great Recession of 2008, on the second day of the company's U.S. Tax Court trial.
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November 04, 2025
Canadian Budget Proposes Slew Of Corporate Tax Breaks
Canada's government aims to introduce immediate expensing for manufacturing, energy, data network infrastructure and scientific research while reinstating first-year write-offs for most capital assets, which would lower its marginal effective corporate tax rate to 13.2%, according to a budget presented late Tuesday.
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November 04, 2025
3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs
A U.S. Supreme Court ruling that gutted deference to agencies took center stage in the Eighth Circuit's recent decision that backed 3M's challenge to transfer pricing rules, signaling the strict statutory analysis that courts may now apply to tax regulations.
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November 04, 2025
Higher Min. Tax Could Help Stem Inequality, G20 Report Says
A higher minimum corporate tax rate with fewer carveouts, tougher inheritance taxes and a global asset registry would help stem economic inequality seen in the vast majority of countries, according to the Group of 20 nations' first report on inequality, published Tuesday.
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November 04, 2025
Insolvent UK Co.'s Ex-Director Fights £2M VAT Fraud Case
The former director of a company in liquidation denied an insolvency specialist's claims that he took part in a value-added tax fraud at the business and is liable for paying about £2 million ($2.6 million), saying the U.K. tax authority has withdrawn its liability notices against him.
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November 03, 2025
Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told
An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determining a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."
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November 03, 2025
4 Ways Justices' Jarkesy Ruling Could Affect Tax Controversy
As lower courts have begun to weigh the U.S. Supreme Court’s 2024 ruling that the SEC’s imposition of civil penalties without a jury trial was unconstitutional, attorneys say the decision could reshape tax disputes and potentially force the IRS to reconsider its approach to enforcement. Here, Law360 examines potential ways the Jarkesy precedent could influence tax controversy.
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November 03, 2025
2 Doctrines Likely To Direct Justices' Review Of Trump Tariffs
When the U.S. Supreme Court hears oral arguments Wednesday over whether President Donald Trump can impose tariffs under the International Emergency Economic Powers Act, it will likely test two doctrines the justices have recently considered: the major questions and nondelegation doctrines.
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November 03, 2025
Kenya Seeks Input On Regs For Min. Tax, Advance Pricing
Kenya's tax authority invited feedback Monday for draft regulations covering its domestic minimum top-up tax and a separate set of draft regulations for its program to offer advance pricing agreements.
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November 03, 2025
US, China Agree To Cut Tariffs, Restrictions In Trade Truce
The United States and China have agreed to a one-year suspension of certain tariffs, export controls and retaliatory trade restrictions, according to statements by the White House and China's Ministry of Commerce.
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November 03, 2025
Veteran Tax Controversy Atty Moves Team To Kostelanetz
A longtime New Jersey tax attorney and three of his associates have joined Kostelanetz LLP, the boutique tax firm announced Monday, saying it expected them to bolster its tax controversy practice and add to its commitment to volunteer work and legal education.
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November 03, 2025
ECJ Asked To Clarify State Aid Tax Rules For Nonprofits
A German court has asked the European Union's top court to rule on whether a tax relief scheme for nonprofit service corporations amounts to state aid under EU law, according to a notice published Monday.
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November 03, 2025
€1.2B Of Campari Owner's Shares Seized In Italian Tax Probe
Italian authorities have seized about €1.2 billion ($1.4 billion) worth of shares in Campari Group as part of a tax investigation into the drink maker's Luxembourg-based majority stakeholder, which announced the asset seizure.
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October 31, 2025
Int'l Tax In October: Deal With China, Halt To Canada Talks
A tentative deal to reduce American tariffs on Chinese goods, ruptured trade talks between the U.S. and Canada, court defeats for the Danish and U.S. tax administrations and an end to the European Union's plan for a financial transaction tax topped the list of international tax news in October. Here, Law360 looks at the biggest developments from the past month.
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October 31, 2025
Up Next At High Court: Tariffs, Fugitives & Contractor Liability
The U.S. Supreme Court will begin its November oral argument session Monday, during which the justices will consider President Donald Trump's authority to impose tariffs on foreign countries under an emergency statute, whether military contractors can be held liable for alleged breaches of contracts in war zones, and if there are time limits for litigants who want to vacate a void judgment. Here, Law360 breaks down the week's oral arguments.
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October 31, 2025
OECD Reports Rise In Failed Advance Pricing Agreements
The number of advance pricing agreements that were rejected or closed without an accord rose 19% last year compared with the previous year, and slightly fewer agreements were granted overall, the Organization for Economic Cooperation and Developmen said Friday.
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October 31, 2025
UK Co. Can't Shake £8.4M Tax On Goods Imported For Repair
A U.K. subsidiary of a U.S. industrial equipment company isn't entitled to recover roughly £8.4 million ($11 million) in value-added tax on goods it brought into the U.K. for repair and servicing, a London tribunal ruled.
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October 31, 2025
OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases
Tax authorities began more than 2,500 mutual agreement procedure cases last year involving transfer pricing, a record number representing a 29% increase from the previous year, the Organization for Economic Cooperation and Development said Friday.
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October 31, 2025
Taxation With Representation: Skadden, Davis Polk
In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.
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October 31, 2025
Australia Issues Guidance On Public Country-By-Country Law
Australia issued guidance Friday on how to comply with its public country-by-country reporting law, including filing instructions, formatting and the information required to be disclosed.
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October 31, 2025
5 Indicted In Germany In €188M VAT Fraud Scheme
Five German residents have been indicted on charges related to their participation in a €188 million ($217 million) value-added tax fraud scheme, European Union authorities said Friday.
Expert Analysis
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Navigating A Potpourri Of Possible Transparency Act Pitfalls
Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.
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How Methods Are Evolving In Textualist Interpretations
Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.
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Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.
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5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.
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How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.
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Litigation Funding Disclosure Key To Open, Impartial Process
Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.
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What NFL Draft Picks Have In Common With Lateral Law Hires
Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.
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Replacing The Stigma Of Menopause With Law Firm Support
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.
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Planning Law Firm Content Calendars: What, When, Where
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.
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Law Firms Should Move From Reactive To Proactive Marketing
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.
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The Big Issues A BigLaw Associates' Union Could Address
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.
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It's Time For A BigLaw Associates' Union
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.