International
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August 12, 2025
Holland & Knight Hires Sen. Cornyn Tax Counsel In DC
The former senior tax counsel for U.S. Sen. John Cornyn, R-Texas, who worked for the lawmaker for almost two decades on appropriations, taxation, banking and other finance-related issues, has joined Holland & Knight LLP's public policy and regulation group.
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August 12, 2025
Trump's Tariffs Add Billions In Revenue, Think Tank Says
President Donald Trump's enacted tariffs are generating billions of dollars more in revenue when compared to duty collections prior to his taking office, and that revenue could be used to reduce the U.S. budget deficit, according to a recent analysis by the Committee for a Responsible Federal Budget.
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August 12, 2025
Federal Revenue From Customs Duties Sharply Higher In July
The federal government raised $28 billion from customs duties, including tariffs, during July, accounting for about 8.3% of federal revenues that month, compared with an average of around 2% in recent history, the U.S. Department of the Treasury reported Tuesday.
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August 12, 2025
Ex-PwC Partner Temporarily Banned From Aussie Tax Work
A former PwC partner is temporarily banned from providing tax services in Australia after authorities determined he made false statements when seeking research and development tax credits, which caused a tax shortfall of over AU$11 million ($7 million), Australia's Tax Practitioners Board said Tuesday.
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August 11, 2025
Data Co. Asks DC Circ. To Revive $22M Guinea Award Bid
A data consulting company has again urged the D.C. Circuit to reverse a lower court order denying its bid to enforce a $22 million arbitral award against Guinea, saying the country wrongly wants the appeals court to ignore long-standing precedent and nix enforcement on jurisdictional grounds.
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August 11, 2025
Tax Court Backs IRS' Denial Of Whistleblower's Award Bid
A whistleblower was correctly denied an award for information about alleged underpayments by a large multinational corporation, the U.S. Tax Court said Monday, finding the information did not substantially contribute to the IRS' action in the case.
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August 11, 2025
Gov'ts Mull Gross Basis Tax For Services In UN Convention
A number of developing countries argued Monday that gross basis taxation is the easiest-to-administer option for overcoming inequitable transfer pricing rules within a protocol on taxing cross-border services in the United Nations framework convention on international tax cooperation.
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August 11, 2025
Goodyear Facing Tax Adjustments Over Intercompany IP Sale
Goodyear Tire & Rubber Co. is planning to challenge proposed IRS adjustments that could undermine the company's ability to offset certain taxes related to an intercompany intellectual property sale, according to a U.S. Securities and Exchange Commission filing.
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August 11, 2025
6th Circ. Orders Eaton To Give Employee Records To IRS
The Sixth Circuit affirmed an Ohio federal judge's order requiring Eaton Corp. to share performance evaluations for Ireland-based workers with the IRS, holding that the agency's interest in investigating potential tax liabilities outweighs Ireland's privacy interest, which the court said was "weak" at best.
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August 11, 2025
Kostelanetz Hires Most Recent DOJ Tax Division Leader
The immediate past head of the U.S. Department of Justice's Tax Division will join Kostelanetz LLP as a partner in Washington, D.C., amid a sweeping restructuring that would split the division's criminal and civil tax functions and place them in the department's main branches.
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August 11, 2025
2nd Circ. Affirms Denial Of Partnership's $22.7M Tax Loss
The U.S. Tax Court correctly found the IRS properly denied a Connecticut partnership's $22.7 million loss deduction because the underlying transactions, which involved a Brazilian company, were tantamount to a disguised property sale, the Second Circuit ruled Monday.
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August 08, 2025
DC Circ. Hands Banker's Estate Win In IRS Whistleblower Bid
A split D.C. Circuit sided with the estate of a former banker at Rabobank in ruling Friday that the Internal Revenue Service used the wrong legal standard to deny him an award for contributing to investigations into two companies' tax avoidance scheme.
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August 08, 2025
Trump Ousts IRS Commissioner Weeks After Confirmation
Billy Long has been removed from his role as Internal Revenue Service commissioner after spending just shy of two months as head of the agency, the White House said Friday.
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August 08, 2025
Italy Cuts Corporate Tax Rate For Capital Goods Investment
Italy began offering a lower corporate tax rate Friday to companies that invest in capital goods, including those that reduce energy consumption, or in hiring new employees, provided they don't lay off workers in either case, according to the Economy and Finance Ministry.
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August 08, 2025
South Korea Probes 49 Foreign Luxury Apartment Buyers
South Korea's National Tax Service said it has launched a tax evasion probe into 49 owners of high-priced apartments who are from foreign countries such as the U.S. and China.
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August 08, 2025
Swiss Metals Group Fears US Tariffs' Impact On Gold
The U.S.-imposed 39% tariffs on Switzerland may "negatively impact" gold trading, a Swiss metals association warned Friday.
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August 08, 2025
11th Circ. Vacates Russian Gas Ex-CFO's Tax Crime Sentence
The Eleventh Circuit vacated a Russian former gas executive's seven-year prison term and order to pay $4 million in restitution to the IRS, saying federal prosecutors were wrongly given extra time to bring charges against him for failing to file income tax returns.
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August 08, 2025
Australia Lifts PwC Bid Ban, Citing Changes After Tax Leak
PwC Australia is no longer banned from bidding on government contracts now that the firm has shown "ethical soundness" after a scandal involving the leak of government tax documents, the Australian Department of Finance said Friday.
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August 08, 2025
Taxation With Representation: Latham, Alston & Bird, Orrick
In this week's Taxation With Representation, fiber optic connector systems maker Amphenol Corp. buys CommScope's connectivity and cable solutions business, Blackstone acquires Enverus from private equity firms, investors buy a majority stake in medical device company HistoSonics Inc., and ESPN swaps an equity stake for the National Football League's NFL Network and other intellectual property.
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August 08, 2025
Germany Seeks Comments On Amendments To Minimum Tax
Germany is looking for comments on amendments to its 15% minimum tax, including on changes to how deferred tax assets are treated and on the elimination of an anti-avoidance rule limiting deductions for licensing expenses, the Finance Ministry said Friday.
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August 08, 2025
Midyear Review: A Look At The Tax Trends Shaping 2025
Tax professionals had a lot to keep up with in the first half of 2025, from congressional action to extend the 2017 GOP tax overhaul to a tumultuous international trade scene. And the back half of the year is poised to be just as busy, with litigation over how the IRS handles employee retention tax credits, an Amazon suit in South Carolina over sales tax, and an uncertain future for global minimum tax rules. Here, dive into our slate of analysis pieces to help guide you through evolving tax litigation and policy.
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August 07, 2025
Toyota Forecasts $9.5B Annual Hit From US Tariffs
U.S. tariffs would cost Toyota Motor Corp. 1.4 trillion yen ($9.5 billion) during its fiscal year ending March 2026, including 450 billion yen in its first quarter, the automaker said Thursday.
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August 07, 2025
Siemens Contests Nix Of $315M Foreign-Dividend Tax Break
Regulatory missteps caused the IRS to wrongly slash $315 million from a foreign-dividend tax deduction Siemens claimed on shareholder payments it received from an overseas affiliate, the medical giant told the U.S. Tax Court.
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August 07, 2025
Switzerland Says 39% Tariff Hits Over Half Of Exports To US
More than half of Switzerland's exports to the United States are now impacted by a 39% tariff, the Swiss government said Thursday after the country's president left Washington, D.C., pledging to continue negotiations to reduce the rate.
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August 07, 2025
Hodgson Russ Adds Former NY Tax Pros To SALT Group
Hodgson Russ LLP has announced that two former New York state and city tax professionals have joined the firm's state and local tax practice in New York City, advising the team on complex regional tax issues.
Expert Analysis
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How Trucking Cos. Can Keep Rolling Under Tariff Burdens
Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.
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$38M Law Firm Settlement Highlights 'Unworthy Client' Perils
A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.
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Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case
A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.
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Evolving Federal Rules Pose Further Obstacles To NY LLC Act
Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.
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Reassessing Corporate Separateness After Explosion Of LLCs
Following the dramatic increase of limited liability companies in the U.S., the Corporate Transparency Act's enactment and the Trump administration's subsequent narrowing of that law, it's worth revisiting the underlying legal principles that govern shell companies in order to remedy the problems that initially motivated the CTA, says Jeff Newton at Omni Bridgeway.
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Crisis Management Lessons From The Parenting Playbook
The parenting skills we use to help our kids through challenges — like rehearsing for stressful situations, modeling confidence and taking time to reset our emotions — can also teach us the fundamentals of leading clients through a corporate crisis, say Deborah Solmor at the Wisconsin Alumni Research Foundation and Cara Peterman at Alston & Bird.
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Adapting To Private Practice: From NY Fed To BigLaw
While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.
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Top 3 Litigation Finance Deal-Killers, And How To Avoid Them
Like all transactions, litigation finance deals can sometimes collapse, but understanding the most common reasons for failure, including a lack of trust or a misunderstanding of deal terms, can help both parties avoid problems, say Rebecca Berrebi at Avenue 33 and Boris Ziser at Schulte Roth.
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A 2-Step System For Choosing A Digital Asset Reporting Path
Under the Internal Revenue Service's new digital asset reporting regulation, each type of asset may have three potential reporting destinations, so a detailed testing framework can help to determine the appropriate path, says Keval Sonecha at Sonecha & Amlani.
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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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.
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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.
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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.