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G7 Deal's Details To Dictate How US Cos. Fare Under Pillar 2

Dylan Moroses

Republicans' international tax changes in their major reconciliation bill that passed Thursday raise questions about the U.S. tax system's ability to coexist with the OECD-designed Pillar Two global minimum tax regime.

Top International Tax Cases To Watch In 2nd Half Of 2025

Natalie Olivo
Senior Tax Correspondent

Major multinational corporations such as 3M and Coca-Cola are expected to continue litigating high-stakes international tax cases in the second half of 2025, including disputes that could test the application of the U.S. Supreme Court's ruling that gutted judicial deference to agencies. Here, Law360 looks at seven key cases to follow the rest of the year.

Federal Tax Policy To Watch In The 2nd Half Of 2025

Stephen K. Cooper
Editor-at-Large

While the extension of the 2017 GOP tax overhaul consumed much of Congress' attention during the first six months of President Donald Trump's second term, lawmakers have other tax issues on their agenda awaiting action. Here, Law360 examines federal tax policy to watch in the second half of the year.

A Look At DOJ's Dropped Case Against Early Crypto Operator

The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.

8 Ways Lawyers Can Protect The Rule Of Law In Their Work

Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.

Despite Dark Clouds, Outlook For US Solar Has Bright Spots

While tariff, tax policy and bankruptcy news seemingly portends unending challenges for the U.S. solar energy industry, signs of continued growth in solar generating capacity and domestic solar manufacturing suggest that there is a path forward, say attorneys at Beveridge & Diamond.

Law School's Missed Lessons: Communicating With Clients

Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

Bill Leaves Renewable Cos. In Dark On Farmland Reporting

A U.S. Senate bill to update disclosure requirements for foreign control of U.S. farmland does not provide much-needed guidance on how to report renewable energy development on agricultural property, leaving significant compliance risks for project developers, say attorneys at Hodgson Russ.

Adapting To Private Practice: From US Rep. To Boutique Firm

My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

IRS Should Work With Industry On Microcaptive Regs

The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

CARES Act Fraud Enforcement Is Unlikely To Slow Down

In the five years since the passage of the Coronavirus Aid, Relief and Economic Security Act, the federal government has devoted massive resources to investigating CARES Act fraud — and all signs suggest the U.S. Department of Justice will continue vigorous enforcement in this area, say attorneys at Kostelanetz.

Spinoff Transaction Considerations For Biotech M&A

Amid current market challenges, boards and management teams of biotech companies can consider several strategies for maximizing value should a spinoff opportunity arise, but not without significant advance planning and careful implementation, particularly in cases that might qualify as tax-free, say attorneys at Paul Hastings.

Senate's 41% Litigation Finance Tax Would Hurt Legal System

The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

Drawbacks For Taxpayers From Justices' Levy Dispute Ruling

The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.

How Energy Cos. Can Prepare For Potential Tax Credit Cuts

The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.

DOJ Has Deep Toolbox For Corporate Immigration Violations

With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.