International
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February 26, 2025
Capital Gains Tax Breaks Lack Proof Of Growth, OECD Says
There is little to no empirical evidence to support the position adopted across most OECD governments that tax relief for capital gains leads to stronger economic growth, broader entrepreneurship and higher savings, the organization said in a report published Wednesday.
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February 26, 2025
Billionaire Claims HMRC Failed To Hold Lawful Tax Inquiry
HM Revenue & Customs failed to lawfully notify the right people in its investigation of tax returns for two partnerships, counsel for a hedge fund billionaire told a London court Wednesday.
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February 26, 2025
ATO Moving Fast Against Outlier Tax Debtors, Chief Says
The Australian Taxation Office is "moving harder and faster" to collect from the 1% of tax debtors who owe about a fifth of the country's roughly AU$50 billion ($31.5 billion) in tax debts, according to prepared remarks by the country's tax commissioner for lawmakers Wednesday.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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Firms Must Rethink How They Train New Lawyers In AI Age
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.
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Think Like A Lawyer: Always Be Closing
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.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
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.
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Lean Into The 'Great Restoration' To Retain Legal Talent
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.
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Fishing Makes Me A Better Lawyer
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.
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A Healthier Legal Industry Starts With Emotional Intelligence
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.
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To Make Your Legal Writing Clear, Emulate A Master Chef
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.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
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.
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Trauma-Informed Legal Approaches For Pro Bono Attorneys
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.
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
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.
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Using A Children's Book Approach In Firm Marketing Content
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.
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New Crypto Reporting Will Require Rigorous Recordkeeping
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.
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Exploring An Alternative Model Of Litigation Finance
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.