International
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September 30, 2025
Altria Loses Out On $38M Refund On Foreign Subsidiaries
Tobacco products maker Altria is not entitled to a $38 million tax refund on foreign subsidiaries, a Virginia federal court found, saying the company was an indirect shareholder through its interest in Anheuser-Busch and therefore owes taxes on its portion of the subsidiaries' income.
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September 30, 2025
UK's Average R&D Tax Credit Claim Jumps 33%
The U.K. has seen the average value of research and development tax credit claims rise despite the overall number of such claims falling in the last tax year, HM Revenue & Customs said Tuesday.
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September 30, 2025
Trump Orders Lumber, Furniture Tariffs To Begin Oct. 14
In an executive order signed Monday evening, President Donald Trump outlined a series of tariff rates on imported lumber and derivative products to be imposed in two weeks.
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September 30, 2025
EU Floats Tax Incentives To Encourage Savings, Investment
The European Commission has issued a blueprint for tax incentives and other measures to help the European Union's member states encourage their residents to set up savings and investment accounts.
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September 29, 2025
Tribal Members Push For Say In Supreme Court Tariff Review
Members of the Blackfeet Nation tribe told the U.S. Supreme Court Monday their inclusion in the justices' review of suits challenging the legality of President Donald Trump's emergency tariffs is crucial to protect Native American rights under federal law.
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September 29, 2025
EU Council Eases Carbon Rules To Reduce Biz Burdens
The Council of the European Union adopted measures Monday aimed at simplifying the bloc's carbon border adjustment mechanism, including exemptions for small importers.
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September 29, 2025
China To Require Platforms To Report Workers' Tax Data
China's government will begin requiring online platform operators to report tax data such as income about all workers for the first time Wednesday, the State Taxation Administration said Monday.
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September 29, 2025
UK Wealth Tax Not Needed, Chancellor Says
Britain doesn't need a wealth tax to cover its spending and debt commitments, Chancellor of the Exchequer Rachel Reeves said Monday.
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September 29, 2025
Argentina Ratifies OECD Tax Treaty Standards
Argentina will begin to align its tax treaties with OECD standards on tax avoidance on Jan. 1, 2026, the organization said Monday after the country ratified the multilateral convention on base erosion and profit shifting.
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September 29, 2025
Calif. Tech Retailer Challenges $3.5M Bill In Tax Court
A California electronics retailer is challenging a nearly $3.5 million tax bill in the U.S. Tax Court based on the company's contention that the IRS failed to recognize that a Hong Kong affiliate carried out a portion of its sales.
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September 29, 2025
IRS Pulls Plug On Proposed Corporate Spinoff Regulations
Proposed regulations for a narrow set of tax-free corporate separation deals known as spinoffs and a multiyear reporting regime for those transactions will be withdrawn, the Internal Revenue Service announced Monday, citing widespread criticism of the framework proposed in January.
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September 29, 2025
IRS Cancels Hearing On Offshore Profit Regulations
The Internal Revenue Service said Monday that it has canceled a public hearing on proposed rules that would require U.S. multinational corporations to create annual shareholder accounts and follow new pooling concepts to account for previously taxed foreign earnings and basis adjustments.
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September 26, 2025
Audits Focused On Profit Shifting, Transfer Pricing, ATO Says
International profit shifting is the subject of about 70% of the Australian Taxation Office's ongoing income tax audits of public and multinational corporations, with transfer pricing of cross-border financing and marketing being major focuses, according to a report published Friday.
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September 26, 2025
Trump Announces 100% Tariff On Drug Imports Starting Oct. 1
President Donald Trump announced a slew of new Section 232 tariffs to be imposed beginning Oct. 1, including a 100% tariff on drug imports and new rates for semi trucks, kitchen cabinets, bathroom vanities and upholstered furniture.
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September 26, 2025
Microsemi, IRS Reach Deal To Settle Transfer Pricing Dispute
The Internal Revenue Service has reached a settlement with semiconductor manufacturer Microsemi to resolve the agency's transfer pricing adjustment regarding an intercompany purchase of semiconductor products, according to U.S. Tax Court filings.
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September 26, 2025
Taxation With Representation: De Brauw, Hengeler Mueller
In this week's Taxation With Representation, power grid operator TenneT Holding sells a stake in its German transmission business to institutional investors, Pfizer Inc. acquires biotechnology company Metsera Inc., and Dutch brewer Heineken NV buys most of Costa Rica's FIFCO beverage and retail operations.
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September 25, 2025
Perrigo Mostly Beats US In $163M Tax Refund Dispute
A Michigan federal court largely sided Thursday with pharmaceutical company Perrigo in a $163 million tax refund case, rejecting the government's claim that the company's transactions with a foreign entity lacked economic substance and were meant only to avoid taxes.
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September 25, 2025
Finland Plans To Raise Taxes On Soft Drinks, Mined Minerals
The Finnish government will increase its soft drink tax based on different levels of sugar content, while also nearly quadrupling its mining mineral tax, the Ministry of Finance announced Thursday.
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September 25, 2025
EU, US Trade Officials Meeting On Tariff Deal
In advance of a meeting Thursday between European and U.S. trade officials, European Commission trade spokesman said discussion topics could include possible rate reductions and tariff exemptions for additional goods under an evolving bilateral framework trade agreement.
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September 25, 2025
Philippine Airlines Challenges $7.1M IRS Bill In Tax Court
Philippine Airlines is disputing $7.1 million in income taxes assessed by the IRS, claiming the agency erred by determining that the airline's gross transportation income was not exempt under the U.S.-Philippines tax treaty, according to a petition filed in the U.S. Tax Court.
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September 25, 2025
Fed. Circ. Upholds China Tariffs From Trump's 1st Term
The Federal Circuit on Thursday blessed a large batch of tariffs on Chinese goods installed by President Donald Trump during his first White House term, turning away a host of importers' claims that the levies had been imposed illegally.
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September 25, 2025
Gov't Warns Of Tax Hit From Pre-Budget Pension Withdrawals
British pension savers that pull cash out of their retirement pots due to pre-Budget jitters will eat into a portion of their tax-free allowance, even if they later change their mind and cancel the withdrawal, the government confirmed Thursday.
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September 25, 2025
Fladgate Says Founders Of Claims Biz Pocketed Tax Refunds
Fladgate LLP has told a London court that the founders of a claims management company swindled tax credits linked to the firm's work on group litigation involving property search companies.
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September 24, 2025
Execs Breached Danish Deal In $2B Tax Case, Court Says
Three men claiming to be pension plan executives who struck a civil settlement with the Danish taxing authority over their role in a $2 billion tax fraud scheme breached their settlement agreement, a New York federal court found, saying the men had not paid back the amount they promised.
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September 24, 2025
Ill. Justices Won't Hear Pepsi's $2.1M Tax Penalty Case
An Illinois appeals court decision allowing $2.1 million in penalties against PepsiCo for categorizing Frito-Lay expatriates' compensation as foreign payroll will stand, as the state's highest court declined to review the dispute Wednesday.
Expert Analysis
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.
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Legal Jeopardy Looms Over Trump's Trade Negotiation Plans
Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.
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What US-India Trade Deal Will Mean For Indian Pharma
Complicated by newly imposed tariffs from the U.S., the outcome of the U.S.-India trade talks is poised to reshape not just trade policy, but also the strategic alignment of the two countries' pharmaceutical ecosystems, says Jashaswi Ghosh at Holon Law Partners.
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Bar Exam Reform Must Expand Beyond A Single Updated Test
Recently released information about the National Conference of Bar Examiners’ new NextGen Uniform Bar Exam highlights why a single test is not ideal for measuring newly licensed lawyers’ competency, demonstrating the need for collaborative development, implementation and reform processes, says Gregory Bordelon at Suffolk University.
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A Simple Way Courts Can Help Attys Avoid AI Hallucinations
As attorneys increasingly rely on generative artificial intelligence for legal research, courts should consider expanding online quality control programs to flag potential hallucinations — permitting counsel to correct mistakes and sparing judges the burden of imposing sanctions, say attorneys at Lankler Siffert & Wohl and Connors.
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The Legal Education Status Quo Is No Longer Tenable
As underscored by the fallout from California’s February bar exam, legal education and licensure are tethered to outdated systems, and the industry must implement several key reforms to remain relevant and responsive to 21st century legal needs, says Matthew Nehmer at The Colleges of Law.
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6 Questions We Should Ask About The Trump Trade Deals
Whenever the text becomes available, certain questions will help determine whether the Trump administration’s trade deals with U.S. trading partners have been crafted to form durable economic relationships, or ephemeral ties likely to break upon interpretive disagreement or a change in political will, says Ted Posner at Baker Botts.
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E-Discovery Quarterly: Rulings On Relevance Redactions
In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.
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Section 1983 Has Promise After End Of Nationwide Injunctions
After the U.S. Supreme Court recently struck down the practice of nationwide injunctions in Trump v. Casa, Section 1983 civil rights suits can provide a better pathway to hold the government accountable — but this will require reforms to qualified immunity, says Marc Levin at the Council on Criminal Justice.
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Playing Soccer Makes Me A Better Lawyer
Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.
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Adapting To Private Practice: From ATF Director To BigLaw
As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.