Law360 Tax Authority: Tax Authority International /tax-authority/international?utm_source=rss&utm_medium=rss&utm_campaign=section Latest articles for: Tax Authority International Copyright 2025 sa¹ú¼Ê´«Ã½. en-US Fri, 21 Nov 2025 18:39:58 +0000 Judge Halts IRS-ICE Info-Sharing Agreement /tax-authority/international/articles/2414463?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2414463 A D.C. federal judge temporarily stopped the IRS on Friday from sharing confidential taxpayer addresses with immigration enforcement officials, saying the agency's disclosures of addresses in August under an information-sharing deal were unlawful. Fri, 21 Nov 2025 17:24:49 +0000 IRS Finalizes Stock Buyback Tax Regs Without 'Funding Rule' /tax-authority/international/articles/2414184?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2414184 The Internal Revenue Service released final regulations Friday for the excise tax on corporations' stock buybacks and similar transactions without the so-called funding rule that would apply the levy to a U.S. subsidiary of a foreign parent company. Fri, 21 Nov 2025 16:27:03 +0000 Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar /tax-authority/international/articles/2414207?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2414207 Deputy Attorney General Todd Blanche’s recent suggestion that the D.C. Bar would be prevented from reviewing misconduct complaints about U.S. Department of Justice attorneys runs contrary to federal statutes, local rules and decades of case law, and sends the troubling message that federal prosecutors are subject to different rules, say attorneys at HWG. Fri, 21 Nov 2025 15:44:45 +0000 Trump Excludes Some Brazilian Foods From Higher Tariffs /tax-authority/international/articles/2414401?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2414401 President Donald Trump has excluded many Brazilian food products from a 40% tariff, including coffee, cocoa, beef and fruits, after receiving word initial progress has been made in ongoing trade negotiations, according to an executive order. Fri, 21 Nov 2025 13:24:41 +0000 Key Issues Facing The IRS Amid Looming Budget Cuts /tax-authority/international/articles/2412813?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2412813 The Internal Revenue Service is facing steep budget cuts in 2026, raising concerns about the agency's ability to handle taxpayer services and enforcement operations that are crucial for bringing in revenue and maintaining compliance with the voluntary system. Here, Law360 looks at the key areas where resource constraints are expected to hamper the IRS and what practitioners can do in response. Fri, 21 Nov 2025 07:05:49 +0000 UK Inheritance Tax Revenue Up 4% So Far In 2025 /tax-authority/international/articles/2414048?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2414048 The government collected £5.2 billion ($6.8 billion) in inheritance tax between April and October, figures published on Friday by Britain's tax authority show, extending a record-setting trend in the 2025/26 financial year. Thu, 20 Nov 2025 19:31:56 +0000 Importers Left With Uncertainty After US-China Trade Truce /tax-authority/international/articles/2413718?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413718 U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation. Thu, 20 Nov 2025 18:24:56 +0000 Treasury To Curtail Tax Credits For Unauthorized Immigrants /tax-authority/international/articles/2413878?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413878 The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday. Thu, 20 Nov 2025 17:16:31 +0000 EU Needs Unified Tax Benefits For Electricity, Experts Say /tax-authority/international/articles/2413798?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413798 The European Union needs a unified approach to tax benefits that would treat electricity more favorably than fossil fuels amid an impasse surrounding its overhaul to the energy taxation system, experts told the European Parliament's tax committee Thursday. Thu, 20 Nov 2025 16:57:53 +0000 8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright /tax-authority/international/articles/2409136?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2409136 The Eighth Circuit’s recent decision invalidating transfer pricing regulations in 3M Co. v. Commissioner may be the most significant tax case implementing Loper Bright's rejection of agency deference as a judicial tool in statutory construction, says Edward Froelich at McDermott. Thu, 20 Nov 2025 14:59:25 +0000 FBAR Penalty Against Ex-Prof Is Constitutional, Court Says /tax-authority/international/articles/2413698?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413698 A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it. Thu, 20 Nov 2025 14:36:30 +0000 Rule Amendments Pave Path For A Privilege Claim 'Offensive' /tax-authority/international/articles/2411229?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2411229 Litigators should consider leveraging forthcoming amendments to the Federal Rules of Civil Procedure, which will require early negotiations of privilege-related discovery claims, by taking an offensive posture toward privilege logs at the outset of discovery, says David Ben-Meir at Ben-Meir Law. Thu, 20 Nov 2025 11:23:12 +0000 EU Council Approves Tax Deal Changes With 5 States /tax-authority/international/articles/2413561?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413561 The Council of the European Union said Thursday that it has approved updates to tax agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland, including new rules to help prevent tax evasion and fraud. Wed, 19 Nov 2025 20:28:53 +0000 Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real /tax-authority/international/articles/2412454?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2412454 A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service. Wed, 19 Nov 2025 17:47:51 +0000 Tax Court Upholds Rejection Of Tax Tipster's Award /tax-authority/international/articles/2413397?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413397 The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday. Wed, 19 Nov 2025 16:31:49 +0000 Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty /tax-authority/international/articles/2413046?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413046 Governments expressed widespread support for adopting measures to strengthen the mutual agreement procedure within a protocol on dispute resolution in the United Nations tax convention during the latest round of negotiations. Wed, 19 Nov 2025 15:35:24 +0000 Tax Court Substance Ruling Offers Silver Lining For Taxpayers /tax-authority/international/articles/2411070?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2411070 Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions. Wed, 19 Nov 2025 14:40:02 +0000 OECD Releases Model Tax Treaty Updates For Amount B /tax-authority/international/articles/2413007?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413007 The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B. Wed, 19 Nov 2025 13:23:19 +0000 EU Tax Compliance Rules Raise €6.8B Annually, EC Finds /tax-authority/international/articles/2412965?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2412965 The European Union's directive for administrative cooperation in taxation, known as DAC, has helped tax authorities generate €6.8 billion ($7.8 billion) a year in extra revenue, the European Commission said in a report Wednesday. Wed, 19 Nov 2025 12:59:45 +0000 Trump's Global Tariffs Curtailed Trade, Data Shows /tax-authority/international/articles/2413013?utm_source=rss&utm_medium=rss&utm_campaign=section /tax-authority/international/articles/2413013 U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.