International
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March 19, 2025
Disclosure Woes Sink £13M Fraud Trial Against Film Execs
Prosecutors have abandoned a decade-long fraud case in which four former managers at a film production company were accused of cheating taxpayers out of £13 million ($17 million) because of insurmountable disclosure failures that sunk the case mid-trial.
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March 18, 2025
Tax Court Sides With IRS Deeming Debt 'Seriously Delinquent'
A Florida man's tax debt was property certified by the Internal Revenue Service as "seriously delinquent" and reported to the U.S. secretary of state to bar him from obtaining or renewing a passport, the U.S. Tax Court said Tuesday.
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March 18, 2025
Danish Wind Farm Co. Wins UK Tax Relief For Study Costs
A Danish wind farm company can claim expenditures on studies and designs associated with constructing wind farms for tax relief purposes, a London appeals court ruled.
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March 18, 2025
5 Jurisdictions Must Improve Tax Transparency, OECD Says
Djibouti, the British Virgin Islands and three other jurisdictions have work to do to improve their compliance with global standards for tax transparency and exchange-of-information measures, according to reports published Tuesday by the Organization for Economic Cooperation and Development.
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March 18, 2025
Trump Hasn't Asked IRS For Immigrants' Tax Info, Gov't Says
The IRS hasn't received any requests from President Donald Trump for immigrants' tax return information and hasn't released any such information to the U.S. Department of Homeland Security, the government told a D.C. federal court in opposing a restraining order sought by immigrant rights groups.
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March 18, 2025
Microsoft Cost-Share Receipts Tax Fight Sent To Trial In Mich.
Microsoft's challenge to Michigan's tax treatment of its cost-sharing agreement receipts is headed to trial after the state's tax tribunal said more proceedings are necessary to determine whether the ownership of the intellectual property in dispute is divided between the company and its affiliates.
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March 18, 2025
EU To Push On With OECD Tax Plan, Official Says
The European Union remains committed to the two-pillar international tax plan designed by the Organization for Economic Cooperation and Development despite U.S. opposition, the EU's tax commissioner said Tuesday.
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March 18, 2025
Canadian PM Candidate Says He'd End Carbon Pricing
Canada's Conservative Party leader and head opposition candidate for prime minister in an upcoming election said he would end the country's nationwide pricing system for greenhouse gas emissions if elected.
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March 17, 2025
Florida Businessman Pleads Guilty To Hiding $20M From IRS
A Florida businessman faces up to five years in prison after he pled guilty Monday to hiding $20 million in Swiss bank accounts from the Internal Revenue Service.
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March 17, 2025
The Tax Angle: Lawmakers Huddle To Mull TCJA
From a look at the three-day legislative retreat held by House Democrats to Ways and Means Republicans meeting behind closed doors to discuss the 2017 GOP tax overhaul, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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March 17, 2025
2% Tax On Ultra-Wealthy Would Raise €67B, Group Says
The implementation of a 2% minimum wealth tax in the European Union on those with over €100 million ($109 million) in assets would generate €67 billion annually while minimizing regressivity in the bloc's tax system, a think tank said.
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March 17, 2025
UK Court Affirms £300K Tax Bill For Ex-Soccer Star's TV Gig
The First-tier Tribunal was correct to find that Sky UK Ltd. employed Phil Thompson, the former captain of the Liverpool Football Club, for television appearances through his intermediary company that is liable for nearly £300,000 ($390,000) in income tax and national insurance contributions, the Upper Tribunal said Monday.
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March 17, 2025
10th Circ. Grapples With Liberty Global's $248M Tax Credit Bid
A Tenth Circuit panel questioned Monday whether Liberty Global is entitled to $248 million in foreign tax credits for the sale of a Japanese affiliate, or if legislation limits the telecommunications giant from classifying the gains as overseas income.
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March 17, 2025
Kleinberg Kaplan Adds Simpson Thacher Atty As Tax Partner
Kleinberg Kaplan announced Monday that it has added a Simpson Thacher & Bartlett LLP attorney to help provide clients with expertise on tax aspects of private investment fund formation and operation, as well as mergers and acquisitions, joint ventures and financings.
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March 17, 2025
Coloradan Owes FBAR Penalty After Failing To Appear
An elderly Colorado man who failed to respond to the government's claim that he owed $482,000 for failing to report his foreign bank accounts is on the hook for the bill, a federal court ruled.
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March 17, 2025
OECD Report Highlights Slow Growth Due To Tariff Impact
The Organization for Economic Cooperation and Development warned Monday that the tariffs between the U.S. and Canada and those between the U.S. and Mexico risk undermining growth at a time when tax revenue is much needed to bring down debt.
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March 14, 2025
Whistleblower Hasn't Proved Retaliation In Tariff Fraud Case
A former employee of two defunct footwear companies has not shown her boss fired her for confronting him about a scheme she alleged he ran to lower tariffs on certain shoes, a New York federal court ruled, letting her claim that he ran the scheme continue to trial.
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March 14, 2025
NZ Planning New Method Of Taxing Foreign Investment Funds
New Zealand is proposing a new method for determining taxable income for purposes of taxing investments of 10% or less in foreign companies by certain migrants in hopes of mitigating issues that were discouraging people from moving to the country, its tax agency said Friday.
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March 14, 2025
Judge Splits $79M Judgment In Danish Tax Fraud Case
A New York federal judge divided a nearly $79 million judgment against four investors and their pension plans after a jury in February found them liable for participating in a tax fraud scheme against the Danish government.
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March 14, 2025
Ex-Greenberg Traurig Atty Ordered To Pay $15.5M To IRS
A former Greenberg Traurig LLP attorney who was sentenced to prison for helping a musician skirt taxes owes $15.5 million in restitution to the Internal Revenue Service, a New York federal judge ruled.
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March 14, 2025
Taxation With Representation: Davis Polk, Paul Weiss
In this week's Taxation With Representation, Mallinckrodt PLC and Endo Inc. combine, Rocket Cos. buys Redfin, and Endo divests its international pharmaceuticals business to Knight Therapeutics Inc.
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March 14, 2025
Struck-Off Lawyer Can't Lift Ban After Misleading HMRC
A former consultant solicitor who misled HM Revenue and Customs to get a refund on stamp duty land tax has failed to have his professional ban lifted as a London court ruled on Friday that the sanction was fair and justified.
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March 13, 2025
Texan Calls $1.7M In FBAR Penalties Unconstitutional
Constitutional law bars the United States from imposing $1.7 million in penalties for failure to report foreign bank accounts, a Texan said in urging a federal court to dismiss such an assessment against her.
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March 13, 2025
Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told
The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.
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March 13, 2025
Australia Clarifying Managed Investment Trust Tax Regime
The Australian government is planning to update its income tax laws to make it clear that trusts ultimately owned by a foreign pension fund can use certain concessional withholding tax rates on eligible distributions to members, the country's assistant treasurer said Thursday.
Expert Analysis
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Impact Of Corporate Transparency Act Ambiguity On Banks
Even though banks generally needn't file beneficial ownership information reports, financial institutions must continue to monitor the status of the Corporate Transparency Act and understand its requirements in case the nationwide injunction that was issued against the CTA earlier this month is overturned, say attorneys at Armstrong Teasdale.
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6 Changes I Would Make If I Ran A Law School
Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.
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Firms Still Have The Edge In Lateral Hiring, But Buyer Beware
Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.
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Think Like A Lawyer: 1 Type Of Case Complexity Stands Out
In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.
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Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity
Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.
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Litigation Inspiration: Reframing Document Review
For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.
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3 Ways To Train Junior Lawyers In 30 Minutes Or Less
Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.
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The Bar Needs More Clarity On The Discovery Objection Rule
Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.