International
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July 29, 2025
Trump Says Britain's Tax On North Sea Oil 'Makes No Sense'
President Donald Trump criticized Tuesday the British government's 78% taxes on North Sea oil as a policy that "makes no sense,"Â a day after speaking with Prime Minister Keir Starmer about trade and other issues.
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July 29, 2025
Ex-IRS Acting Commissioner Joins KPMG's DC Office
A former senior Internal Revenue Service employee who served as the agency's acting commissioner this year has joined KPMG LLP's Washington national tax practice as a senior managing director, the firm announced.
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July 29, 2025
Switzerland Signs Tax Treaty Update With Belgium
Switzerland reached an agreement with Belgium to add an anti-abuse clause focused on the primary purpose of transactions to the countries' tax treaty while similar changes to the Serbian-Swiss treaty have come into force, the Swiss finance ministry said Tuesday.
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July 28, 2025
New IRS Chief Rejects 'Wizard Of Oz'-Style Leadership
New Internal Revenue Commissioner Billy Long vowed Monday to engage more directly with agency employees to improve taxpayer service, emphasizing that he does not want to be a "Wizard of Oz"-style leader hiding behind a curtain.
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July 28, 2025
US, Japanese Businessman Settle $11.6M FBAR Dispute
A Japanese businessman and the federal government have settled their $11.6 million tax filing dispute after the man claimed a language barrier was to blame and the U.S. tried to push past a jury's verdict, according to a Hawaii federal court filing.
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July 28, 2025
Britons Fear Impact Of Inheritance Tax Change On Pensions
Four out of 10 people in Britain are concerned about the government's decision to bring pensions within the scope of inheritance tax, according to a survey by a consultancy on Monday.
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July 25, 2025
Trump Trade Deals Do Little To Ease Importers' Concerns
President Donald Trump's recently announced framework trade deals offer new insight into tariff rates for several countries come Aug. 1, but experts say unanswered questions about those agreements and others still at large continue to stifle longer-term planning, leaving importers in uncertain territory.
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July 25, 2025
Ex-Credit Suisse Client Gets 2½ Years For Hiding $90M In Assets
A Florida federal judge on Friday sentenced a Colombian-American businesswoman and former Credit Suisse client to two-and-a-half years in prison for conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.
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July 25, 2025
Russia Loses Bid To Nix Enforcement Of $63B Awards
A Singapore court on Friday denied Russia's bid to dodge litigation seeking the enforcement of more than $63 billion in arbitral awards issued to former investors in Yukos Oil Co. 11 years ago, rejecting the Kremlin's argument that it never agreed to arbitrate the dispute.
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July 25, 2025
Swiss Withholding Tax Counts For Minimum Tax, Gov't Says
Swiss multinational businesses will need to take into account Swiss withholding taxes on distributions to owners when calculating liabilities for the domestic component of the 15% global minimum tax, but not taxes paid on those distributions abroad, the Federal Tax Administration said in guidance.
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July 25, 2025
Rising Star: Gibson Dunn's Michael Q. Cannon
Michael Q. Cannon of Gibson Dunn & Crutcher LLP has been the lead attorney on several high-profile cases, including playing a key role in advising on the tax aspects of the world's largest merger and acquisition deal in 2023, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 25, 2025
IRS Provides Guidance Meant To Speed Up Corporate Audits
The Internal Revenue Service released guidance Friday that aims to make audits more efficient for corporate taxpayers, including by phasing out a document request process taxpayers had criticized as time-consuming and of little value.
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July 25, 2025
6 Things To Know About Illinois' New Tax Landscape
Illinois' latest budget has altered the state's tax system for 2025 and beyond, including by offering three tax amnesty programs, making significant changes to corporate tax law and implementing a relatively new concept for the sourcing of pass-through entity sales. Here, Law360 looks at aspects that state tax practitioners say are crucial to their clients.
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July 25, 2025
France Says It Will Accept Amount B Decisions
France will accept transfer pricing decisions made under the simplified and streamlined OECD process known as Amount B, provided they're made by an eligible low-capacity country that has a bilateral tax treaty with France, the French government said.
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July 25, 2025
Legal Org. Urges DC Circ. To Reject Trump's Tariff Powers
The D.C. Circuit should affirm a ruling that sided with toy makers and blocked President Donald Trump from using an international economic law to impose emergency tariffs because the law does not give the president the authority he claims, a legal organization argued.
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July 25, 2025
Taxation With Representation: Weil, Freshfields, Linklaters
In this week's Taxation With Representation, CC Capital and One Investment Management acquire Insignia Financial Ltd., catering giant Compass Group PLC acquires Dutch food and hospitality company Vermaat Groep BV, drugmaker Sanofi acquires biotech company Vicebio, and The Ether Machine launches as a public company.
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July 25, 2025
UK Adds Spain, Guernsey To Approved Minimum Tax List
The U.K. government added Spain and the island of Guernsey to its list of jurisdictions that have implemented the Organization for Economic Cooperation and Development's global corporate minimum tax mechanisms.
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July 24, 2025
EU Prepared To Impose €93B In Tariffs On US Goods
The European Commission voted Thursday to impose tariffs on €93 billion ($109 billion) worth of U.S. goods if no trade deal is reached by August as the two sides continue negotiations.
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July 24, 2025
Rising Star: McDermott's Michael Bruno
Michael Bruno of McDermott Will & Emery LLP was tapped as lead tax counsel by two legendary athletes — Lionel Messi and Stephen Curry — for the rollouts of their respective beverage brands, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.
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July 24, 2025
GOP Reps. Urge IRS To Roll Back Economic Substance Ruling
The Internal Revenue Service should withdraw a revenue ruling that invokes the economic substance doctrine to disregard certain intercompany transactions, 20 Republicans on the House Ways and Means Committee said Thursday, arguing it leaves taxpayers uncertain about how to apply partnership tax laws to commercial transactions.
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July 24, 2025
EU Considering Overhaul Of VAT On Traveling
The European Commission is seeking comments on how best to adjust its value-added tax rules for travel agents and passenger transportation, saying Thursday that the current rules are outdated and overly complex, leading to economic distortions and lower tax revenue.
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July 24, 2025
German Court Convicts 4th In €195M VAT Fraud Scheme
A fourth person has been convicted in connection with a €195 million ($229.3 million) value-added tax fraud scheme, this time in a German regional court, the European Public Prosecutor's Office said.
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July 24, 2025
OECD Pricing Tax Lacks Gains For Many Nations, Report Says
The OECD's subject-to-tax rule would not affect any treaties between the organization's members and major developing countries, while the United Nations' alternative version could raise revenue more effectively, according to a report from the Group of 24 nations and an intergovernmental think tank.Â
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July 24, 2025
Tax Reforms Key To Thailand Social Protections, OECD Says
Spending on nonhealthcare social protections in Thailand makes up 2.1% of its gross domestic product, and raising that spending will require juiced tax revenue, the Organization for Economic Cooperation and Development said Thursday while suggesting avenues for such an increase.
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July 23, 2025
Fla. Man Gets 5 Years In Jail For Hiding Swiss Bank Accounts
A Florida federal judge on Wednesday sentenced a Miami man to five years in prison on a conspiracy-related count in connection with evading taxes on approximately $20 million he held in Swiss bank accounts and setting up trusts in an attempt to hide assets.
Top Int'l Trade Policy To Watch In The 2nd Half Of 2025
Pervasive uncertainty surrounds international trade policy as the U.S. takes mercurial swings at the world with tariffs, including a quelled-for-now quasi embargo of China, and while lasting economic fallout hasn't materialized at home, partners abroad are aiming to replace reliance on the American market. Here, Law360 looks ahead at international trade policy during the latter half of one of the most consequential years in the field's history.

EU, US Agree To 15% Tariff Rate For Most Sectors
The European Union and the U.S. government have reached a deal for a 15% U.S. tariff rate on EU goods from most industry sectors, including cars, semiconductor chips and pharmaceuticals, avoiding the 30% rate that was due to take effect next month.

Top International Tax Policy To Watch In 2nd Half Of 2025
The attempt by the U.S. to win an exemption for its companies from the 15% global minimum tax is the most consequential saga currently in international tax policy, but the tumultuous trade scene and anticipated guidance on Congress' tax code tinkering are also in the minds of tax professionals. Here, Law360 looks at what further changes are likely in the volatile global tax landscape during the second half of the year.
Featured Stories
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Trump Trade Deals Do Little To Ease Importers' Concerns
President Donald Trump's recently announced framework trade deals offer new insight into tariff rates for several countries come Aug. 1, but experts say unanswered questions about those agreements and others still at large continue to stifle longer-term planning, leaving importers in uncertain territory.
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Top International Tax Policy To Watch In 2nd Half Of 2025
The attempt by the U.S. to win an exemption for its companies from the 15% global minimum tax is the most consequential saga currently in international tax policy, but the tumultuous trade scene and anticipated guidance on Congress' tax code tinkering are also in the minds of tax professionals. Here, Law360 looks at what further changes are likely in the volatile global tax landscape during the second half of the year.
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6 Things To Know About Illinois' New Tax Landscape
Illinois' latest budget has altered the state's tax system for 2025 and beyond, including by offering three tax amnesty programs, making significant changes to corporate tax law and implementing a relatively new concept for the sourcing of pass-through entity sales. Here, Law360 looks at aspects that state tax practitioners say are crucial to their clients.
Expert Analysis
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Adapting To Private Practice: From ATF Director To BigLaw
As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.
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How Cos. In China Can Tailor Compliance Amid FCPA Shifts
The U.S. Department of Justice’s recently updated Foreign Corrupt Practices Act enforcement guidelines create a fluid business environment for companies operating in China that will require a customized compliance approach to navigate both countries’ corporate and legal systems, say attorneys at Dickinson Wright.
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Playing Baseball Makes Me A Better Lawyer
Playing baseball in college, and now Wiffle ball in a local league, has taught me that teamwork, mental endurance and emotional intelligence are not only important to success in the sport, but also to success as a trial attorney, says Kevan Dorsey at Swift Currie.
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4 Former Justices Would Likely Frown On Litigation Funding
As courts increasingly confront cases involving hidden litigation finance contracts, the jurisprudence of four former U.S. Supreme Court justices establishes a constitutional framework that risks erosion by undisclosed financial interests, says Roland Eisenhuth at the American Property Casualty Insurance Association.
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How Attys Can Use AI To Surface Narratives In E-Discovery
E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.
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AbbVie Frees Taxpayers From M&A Capital Loss Limitations
The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.
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ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'
The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.
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Can Companies Add Tariffs Back To Earnings Calculations?
With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.
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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.
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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.
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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.
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Navigating Antitrust Risks When Responding To Tariffs
Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.
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Key Points From HMRC's Tax Reform Proposals
Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.