International

  • February 26, 2025

    Coke's $2.7B Tax Bill Due To 'Bait And Switch,' 11th Circ. Told

    Coca-Cola urged the Eleventh Circuit to reverse a U.S. Tax Court decision putting the beverage giant on the hook for $2.7 billion in taxes, arguing the ruling excused the IRS' "blatant bait and switch" regarding how it allocates income from foreign affiliates.

  • February 26, 2025

    Tax Overhaul Designer Named Top Tax Adviser To Treasury

    An attorney who worked for Exxon Mobil and helped design the 2017 tax overhaul in President Donald Trump's first term has been appointed to serve as a top tax adviser to Treasury Secretary Scott Bessent, Treasury announced Wednesday.

  • February 25, 2025

    Promised German Tax Cuts Could Come As Deficit Climbs

    With the Christian Democrats, winners of Germany's election, having promised to pursue tax cuts, the country's Ministry of Finance revealed Tuesday that the budget deficit reached €18.7 billion ($19.7 billion) last month.

  • February 25, 2025

    Canada Seeking Feedback On EV Supply Chain Tax Credit

    Canada's government is looking for public input on a plan to introduce a tax credit designed to help support the expansion of electric vehicle manufacturing.

  • February 25, 2025

    Brazil Starts Corp. Tax Compliance Benefit Program

    Companies in Brazil that are up to date and compliant with their tax obligations will be offered benefits for doing so as part of a pilot program, the country's tax service said.

  • February 24, 2025

    Eaton's Foreign Tax Credits Rejected By Tax Court

    The U.S. Tax Court rejected foreign tax credits that Eaton Corp. had claimed on its lower-tier overseas entities' income taxes for 2007 and 2008, saying in a Monday opinion that its overseas ownership structure had disqualified the multinational power management company.

  • February 24, 2025

    Investor Settles In $2.1B Danish Tax Fraud Case

    A U.S. investor who was among those accused by Denmark's tax agency of participating in a $2.1 billion tax fraud scheme related to fraudulently claiming refunds on tax withheld from stock dividends has reached a settlement, according to New York federal court documents filed Monday.

  • February 24, 2025

    Denmark Argues Misrepresentation Led To £1.4B Tax Refunds

    Denmark's tax authority told the High Court of Justice on Monday that it would not have paid out billions in refunds to a British trader and others accused of involvement in a fraudulent trading scheme had they not submitted forms purporting to show eligibility for tax refunds.

  • February 24, 2025

    Ex-Goldman Exec Owes For Not Filing FBARs, US Says

    A former Goldman Sachs banking executive who lives in Australia owes penalties to the Internal Revenue Service for failing to report foreign bank accounts she held, the U.S. government told a D.C. federal court.

  • February 24, 2025

    NZ Reviewing Charity Business Income Tax Exemption

    New Zealand is looking for comments on its internationally unique tax structure that allows charities and not-for-profits to conduct business activities tax-free in order to raise money, asking stakeholders whether such a regime continues to be effective, the country's tax agency said Monday.

  • February 24, 2025

    Apple To Invest $500B In US Over 4 Years As Tariffs Mount

    Apple said Monday that it would invest $500 billion in the U.S. over the next four years, weeks after President Donald Trump placed a 10% tariff on goods from China, where the company sources components for its products, and threatened tariffs on semiconductors.

  • February 24, 2025

    Aussie Tax Office Agrees To Step Up Safeguards For AI

    The Australian Taxation Office said Monday that it will implement seven recommendations made by a national auditing body regarding the agency's adoption of artificial intelligence tools, including looking closer at potential data ethics risks and the overall development of the programs.

  • February 24, 2025

    High Court Won't Hear Tax Tipster's $690M Award Claim

    The U.S. Supreme Court declined on Monday to review a man's claim for a $690 million whistleblower award for undercover recordings and tips he gave the IRS that he said led to the arrests of Swiss bankers and the success of an offshore tax disclosure program.

  • February 24, 2025

    OECD Issues Consolidated Guidance On Amount B

    The OECD issued consolidated guidance Monday that it put out throughout last year for an internationally agreed-upon method to apply the arm's-length principle to pricing baseline marketing and distribution activities by multinational corporations, known as Amount B of Pillar One.

  • February 21, 2025

    Trump Says Tariffs Coming For Countries With DSTs

    President Donald Trump's administration will impose tariffs on countries with taxes that disproportionately affect American companies, such as digital services taxes, which mainly apply to tech giants, according to a memorandum released late Friday.

  • February 21, 2025

    The Tax Angle: ABA Midyear Tax Meeting

    With a lack of government officials attending the American Bar Association's midyear tax meeting, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • February 21, 2025

    China Says Tax Deferral Boosted Foreign Reinvestment

    A tax regime exempting foreign investors from withholding taxes on certain profits generated by their China-based businesses as long as those profits are directly reinvested in projects in China led to a 15% year-over-year increase in foreign reinvestment, the country's tax administration said Friday.

  • February 21, 2025

    French 2% Minimum Wealth Tax Advances In Parliament

    French households with assets worth more than €100 million ($104.6 million) would be subject to a 2% minimum tax on their net worth annually under a top-up wealth tax proposal approved by the lower house of France's Parliament.

  • February 21, 2025

    IRS, Engineer Resolve Fight Over $5.5M In FBAR Penalties

    The U.S. government and an engineer have resolved a dispute over $5.5 million in penalties and interest regarding the nondisclosure of assets in her foreign accounts from 2009 to 2012, according to a judgment entered by a California federal court.

  • February 21, 2025

    Australia Lays Out Eligibility For Hydrogen, Mineral Credits

    The Australian Taxation Office released guidance for companies hoping to claim either of a pair of new tax incentives aimed at hydrogen and critical mineral production, including eligibility requirements and how to claim the credits.

  • February 21, 2025

    DLA Piper Tax Attorney Jumps To Vedder Price In Chicago

    Vedder Price PC has expanded its Chicago office with the addition of a skilled tax attorney who brings nearly 30 years of experience, most recently with DLA Piper.

  • February 21, 2025

    Taxation With Representation: Kirkland, V&E, Cravath, Dechert

    In this week's Taxation With Representation, Diamondback Energy buys Midland Basin assets from another oil and natural gas company, GTCR closes its second strategic growth fund, Light & Wonder Inc. buys Grover Gaming's assets, and Barings acquires Artemis Real Estate Partners.

  • February 21, 2025

    EU Tax Blacklist Needs New Criteria, Tax Pros Say

    The European Union's list of uncooperative tax jurisdictions needs new criteria to tackle the problem of corporate tax avoidance and harmful tax practices, tax campaigners claimed Friday.

  • February 21, 2025

    UK, Andorra Agree To Double-Tax Treaty

    The U.K. and Andorra have reached an agreement on a treaty to prevent double taxation that will go into effect once it is approved by both countries' legislatures, HM Revenue & Customs said Friday.

  • February 21, 2025

    UK Sticks With Inheritance Tax Changes Amid Higher Revenue

    A U.K. budget surplus, reported Friday, indicates that the Labour government shows no sign of compromising with its inheritance tax changes as tax receipts rise despite the implications for middle-class families and farmers.

Expert Analysis

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

  • Trauma-Informed Legal Approaches For Pro Bono Attorneys

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    As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.

  • How Attys Can Avoid Pitfalls When Withdrawing From A Case

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    The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.

  • Using A Children's Book Approach In Firm Marketing Content

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    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

  • New Crypto Reporting Will Require Rigorous Recordkeeping

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    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

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