International
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July 30, 2025
Updates To Switzerland-France Tax Treaty Enter Into Force
Changes to Switzerland and France's tax treaty have come into effect, including new rules for cross-border remote workers and measures to target aggressive tax planning, the Swiss government said.
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July 30, 2025
Roughly 34K Cos. Have Claimed UAE Late Registration Relief
Nearly 34,000 corporations have taken advantage of the United Arab Emirates' penalty waiver for late tax registration applications, the county's tax authority announced.
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July 30, 2025
OECD Releases Spreadsheets For Min. Tax, Crypto Reporting
The OECD released a blueprint Wednesday for tax authorities to identify errors in tax returns shared by other authorities pursuant to the 15% global minimum tax, along with an updated blueprint for authorities to swap information on cryptocurrency holdings.
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July 30, 2025
UK Gov't Forced To Repay £48.7M In Pension Overtaxation
The government has had to hand back £48.7 million ($64.7 million) in the past three months to Britons who paid too much tax when tapping into their pension savings, figures revealed Wednesday, as experts say a fix for the long-running tax provision so far has shown little effect.
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July 29, 2025
IRS To Permit Corp. AMT Top-Down Election For Partnerships
The IRS said Tuesday that revised proposed rules for the corporate alternative minimum tax will accommodate different approaches to calculating a partnership's investment income, including the top-down approach permitting a corporate partner to use figures that the partner reported in its own financial statement.
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July 29, 2025
Economists Decry Federal Budget's Looser Interest Deduction
It's regrettable that Congress loosened rules allowing companies to deduct interest costs from tax liabilities in its latest budget, which as a whole is poised to worsen the country's fiscal trajectory while prompting higher interest rates, a panel of economists said Tuesday.
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July 29, 2025
Trump To Make Call On Further Delay Of Higher China Tariffs
President Donald Trump will decide whether to extend a tariff delay another 90 days for Chinese imports after U.S. Treasury Secretary Scott Bessent and U.S. Trade Representative Jamieson Greer met with Chinese officials to discuss trade matters, the officials told reporters Tuesday in Stockholm.
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July 29, 2025
Ensure Energy Tax Credit Limit On Foreign Cos., Letter Says
The U.S. Department of the Treasury should publish guidance aimed at preventing foreign corporations from circumventing the new budget law's limits on energy tax credits by starting construction before the restrictions kick in, a solar technology and manufacturing company said in a letter Tuesday.
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July 29, 2025
Top Int'l Trade Policy To Watch In The 2nd Half Of 2025
Pervasive uncertainty surrounds international trade policy as the U.S. takes mercurial swings at the world with tariffs, including a quelled-for-now quasi embargo of China, and while lasting economic fallout hasn't materialized at home, partners abroad are aiming to replace reliance on the American market. Here, Law360 looks ahead at international trade policy during the latter half of one of the most consequential years in the field's history.
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July 29, 2025
Trump Says Britain's Tax On North Sea Oil 'Makes No Sense'
President Donald Trump criticized Tuesday the British government's 78% taxes on North Sea oil as a policy that "makes no sense," a day after speaking with Prime Minister Keir Starmer about trade and other issues.
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July 29, 2025
Ex-IRS Acting Commissioner Joins KPMG's DC Office
A former senior Internal Revenue Service employee who served as the agency's acting commissioner this year has joined KPMG LLP's Washington national tax practice as a senior managing director, the firm announced.
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July 29, 2025
Switzerland Signs Tax Treaty Update With Belgium
Switzerland reached an agreement with Belgium to add an anti-abuse clause focused on the primary purpose of transactions to the countries' tax treaty while similar changes to the Serbian-Swiss treaty have come into force, the Swiss finance ministry said Tuesday.
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July 28, 2025
New IRS Chief Rejects 'Wizard Of Oz'-Style Leadership
New Internal Revenue Commissioner Billy Long vowed Monday to engage more directly with agency employees to improve taxpayer service, emphasizing that he does not want to be a "Wizard of Oz"-style leader hiding behind a curtain.
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July 28, 2025
EU, US Agree To 15% Tariff Rate For Most Sectors
The European Union and the U.S. government have reached a deal for a 15% U.S. tariff rate on EU goods from most industry sectors, including cars, semiconductor chips and pharmaceuticals, avoiding the 30% rate that was due to take effect next month.
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July 28, 2025
US, Japanese Businessman Settle $11.6M FBAR Dispute
A Japanese businessman and the federal government have settled their $11.6 million tax filing dispute after the man claimed a language barrier was to blame and the U.S. tried to push past a jury's verdict, according to a Hawaii federal court filing.
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July 28, 2025
Britons Fear Impact Of Inheritance Tax Change On Pensions
Four out of 10 people in Britain are concerned about the government's decision to bring pensions within the scope of inheritance tax, according to a survey by a consultancy on Monday.
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July 25, 2025
Trump Trade Deals Do Little To Ease Importers' Concerns
President Donald Trump's recently announced framework trade deals offer new insight into tariff rates for several countries come Aug. 1, but experts say unanswered questions about those agreements and others still at large continue to stifle longer-term planning, leaving importers in uncertain territory.
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July 25, 2025
Ex-Credit Suisse Client Gets 2½ Years For Hiding Assets
A Florida federal judge on Friday sentenced a Colombian-American businesswoman and former Credit Suisse client to two and a half years in prison for conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.
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July 25, 2025
Russia Loses Bid To Nix Enforcement Of $63B Awards
A Singapore court on Friday denied Russia's bid to dodge litigation seeking the enforcement of more than $63 billion in arbitral awards issued to former investors in Yukos Oil Co. 11 years ago, rejecting the Kremlin's argument that it never agreed to arbitrate the dispute.
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July 25, 2025
Top International Tax Policy To Watch In 2nd Half Of 2025
The attempt by the U.S. to win an exemption for its companies from the 15% global minimum tax is the most consequential saga currently in international tax policy, but the tumultuous trade scene and anticipated guidance on Congress' tax code tinkering are also in the minds of tax professionals. Here, Law360 looks at what further changes are likely in the volatile global tax landscape during the second half of the year.
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July 25, 2025
Swiss Withholding Tax Counts For Minimum Tax, Gov't Says
Swiss multinational businesses will need to take into account Swiss withholding taxes on distributions to owners when calculating liabilities for the domestic component of the 15% global minimum tax, but not taxes paid on those distributions abroad, the Federal Tax Administration said in guidance.
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July 25, 2025
Rising Star: Gibson Dunn's Michael Q. Cannon
Michael Q. Cannon of Gibson Dunn & Crutcher LLP has been the lead attorney on several high-profile cases, including playing a key role in advising on the tax aspects of the world's largest merger and acquisition deal in 2023, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 25, 2025
IRS Provides Guidance Meant To Speed Up Corporate Audits
The Internal Revenue Service released guidance Friday that aims to make audits more efficient for corporate taxpayers, including by phasing out a document request process taxpayers had criticized as time-consuming and of little value.
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July 25, 2025
6 Things To Know About Illinois' New Tax Landscape
Illinois' latest budget has altered the state's tax system for 2025 and beyond, including by offering three tax amnesty programs, making significant changes to corporate tax law and implementing a relatively new concept for the sourcing of pass-through entity sales. Here, Law360 looks at aspects that state tax practitioners say are crucial to their clients.
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July 25, 2025
France Says It Will Accept Amount B Decisions
France will accept transfer pricing decisions made under the simplified and streamlined OECD process known as Amount B, provided they're made by an eligible low-capacity country that has a bilateral tax treaty with France, the French government said.
Expert Analysis
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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.
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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.
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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.
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How To Accelerate Your Post-Attorney Career Transition
Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.
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Tariffs And FCA Create Perfect Storm For Importers
The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.
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US Reassessment Of OECD Tax Deal Is Right Move
The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.
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Measuring And Mitigating Harm From Discriminatory Taxes
In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.
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Adapting To Private Practice: From DOJ Leadership To BigLaw
The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.
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How The CRE Industry Is Adapting To Tariff Uncertainty
Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.
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Law Firm Executive Orders Create A Legal Ethics Minefield
Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.
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Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike
The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.
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Firms Must Embrace Alternative Billing Models Or Fall Behind
As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.
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How Attorneys Can Master The Art Of On-Camera Presence
As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.