International
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March 24, 2025
McDermott Hires Skadden Partner To Lead London Tax Office
McDermott Will & Emery LLP announced Monday that it has chosen a former Skadden Arps Slate Meagher & Flom LLP partner to serve as the new leader of the firm's U.K. tax office in London.
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March 24, 2025
Burden Of Proof Is IRS' For $2.3M Bill, Kyocera Tells Tax Court
The Internal Revenue Service should bear the burden of proof in making adjustments to an amended return filed by electronics-maker Kyocera, the company argued as it urged the U.S. Tax Court to review an IRS notice saying the company owes $2.3 million for 2018.
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March 24, 2025
Caribbean Bank, CEO Accused Of Helping In £415M VAT Fraud
A Caribbean bank and its former CEO "knowingly" assisted in the commission of a £415 million ($536 million) value-added tax fraud, the creditors of a company allegedly linked to the scam said on the first day of a London trial Monday.
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March 24, 2025
TV Star Banned As Co. Director Over Failure To Pay £1M Tax
A U.K. reality television star has been banned as the director of his media company after it failed to pay more than £1 million ($1.3 million) in taxes, the government's insolvency agency said Monday.
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March 24, 2025
FinCEN Exempts US Businesses From Disclosure Rules
The U.S. Department of the Treasury's financial crimes unit issued interim final rules that exempt domestic businesses from contested reporting regulations, which the department had previously signaled it would narrow to include only foreign companies registered stateside.
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March 24, 2025
UK Gov't Considers DST Changes To Prevent US Tariffs
The Labour government may be considering changes to the digital services tax as part of talks with the U.S. administration to prevent tariffs being imposed on Britain, Chancellor of the Exchequer Rachel Reeves suggested in a TV interview.
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March 21, 2025
Court Sours On Tribunal's Sweets Ruling For Marshmallows
The First-tier Tribunal applied a faulty interpretation of value-added tax law to rule that jumbo-size marshmallows are exempt from VAT, a U.K. Court of Appeal panel said Friday, remanding the £473,000 ($611,000) dispute back to the tribunal.
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March 21, 2025
Ex-UBS North America CEO Agrees To $4.9M FBAR Judgment
The former North American CEO for Swiss bank UBS on Friday agreed to a $4.9 million judgment to end claims that he failed to file timely or accurate foreign bank account reports with the Internal Revenue Service between 2003 and 2013.
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March 21, 2025
US-Swiss Agreement Exempts Retirees' Dividends, IRS Says
U.S. retirement accounts, including trusts, qualified annuity plans and other schemes, are exempt from Swiss taxes on dividends from Swiss companies in which they don't own a controlling interest, according to a U.S.-Switzerland competent authority agreement released Friday by the IRS.
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March 21, 2025
Taxation With Representation: Cravath, Paul Weiss, Cooley
In this week's Taxation With Representation, Google acquires Wiz, QXO Inc. acquires Beacon Roofing Supply, and the Boston Celtics are bought by a group led by private equity firm co-founder William Chisholm.
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March 21, 2025
Informal Money Transfers Launder £2B Annually, HMRC Warns
Criminals in the U.K. are laundering an estimated £2 billion (£2.6 billion) every year via informal money transfer services, HM Revenue and Customs has warned.
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March 21, 2025
Spanish Lottery Co. Accused Of Tax Insurance Market Breach
Spain's competition authority said Friday it is investigating a lottery company on suspicion of suppressing the marketing of tax insurance coverage for lottery winners.
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March 20, 2025
Corp. Taxes Should Match Climate Goals, OECD Paper Says
Countries that want to reduce carbon emissions should design corporate income taxes that align with climate policy objectives, including providing incentives for clean energy investments, according to an OECD working paper released Thursday.
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March 20, 2025
Frost Brown Adds Former Houston City Atty To Finance Team
Frost Brown Todd LLP announced that it has hired an attorney from the ranks of Houston's city government to strengthen its public finance group, adding his expertise in state and local government operations, taxation and economic development.
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March 20, 2025
PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.
Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified. Â
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March 20, 2025
90% Of Crypto Sellers Conceal Income, Danish Data Shows
Danish Tax Agency data shows more than 90% of cryptocurrency sellers don't report that income and that many have shifted to foreign platforms to avoid domestic reporting rules, the EU Tax Observatory said in a working paper, suggesting international coordination is essential to tax crypto effectively.
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March 20, 2025
Prudential's £9.3M Fees To Silverfleet Taxable, HMRC Argues
Prudential's payments of £9.3 million ($12 million) to an investment firm are taxable even though the fees were for services the firm carried out when the two companies were part of the same group, the tax authority's counsel told the U.K. Supreme Court on Thursday.
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March 19, 2025
IRS Hunter Biden Whistleblower Named Deputy Criminal Chief
An Internal Revenue Service special agent who accused the U.S. Department of Justice of mishandling an investigation into former President Joe Biden's son has been named deputy chief in the IRS Criminal Investigation division, the agency said Wednesday.
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March 19, 2025
Coke's $2.7B Tax Bill Arbitrary, Business Groups Tell 11th Circ.
Three industry groups asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming that the Internal Revenue Service could raise Coca-Cola's taxes by $2.7 billion, saying in friend-of-the-court briefs that the IRS acted arbitrarily in hiking the Atlanta-based beverage giant's tax liability.
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March 19, 2025
Sweden Proposes Cutting Some Green Energy Tax Breaks
Sweden's Ministry of Finance is proposing that the government slash a pair of green energy tax benefits, one for the installation of solar panels and the other related to the microproduction of renewable energy.
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March 19, 2025
Technical, Policy Questions Still Swirl Around Amount B
U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.
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March 19, 2025
DC Judge Won't Preemptively Stop IRS Data Sharing With DHS
A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their bid for a court order that would preemptively block any information transfer.
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March 19, 2025
Switzerland, Zimbabwe Sign Tax Treaty
Switzerland and Zimbabwe signed an agreement Wednesday for a treaty to avoid double taxation of income, an expansion of the Swiss treaty network in southern Africa that has been welcomed by cantons and businesses, according to Switzerland's competent authority.
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March 19, 2025
Law360 Announces The Members Of Its 2025 Editorial Boards
Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.
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March 19, 2025
Group Status Prohibits VAT, Prudential Tells UK Top Court
Prudential disputed a value-added tax claim on £9.3 million ($12.1 million) in performance fees at the U.K. Supreme Court on Wednesday on the grounds that the business providing the services was a part of the same group as Prudential for tax purposes.Â
Expert Analysis
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.
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4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.
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What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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4 PR Pointers When Your Case Is In The News
Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.
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Unpacking The Proposed Production Tax Credit Regulations
Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.
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10 Considerations For Litigating A New York Tax Case
While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.
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Law Firm Strategies For Successfully Navigating 2024 Trends
Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.
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Attorneys' Busiest Times Can Be Business Opportunities
Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.
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How Attorneys Can Be More Efficient This Holiday Season
Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.
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How Clients May Use AI To Monitor Attorneys
Excerpt from
Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.