International

  • June 08, 2026

    Liberty Global Seeks Rehearing In $2.4B Tax Substance Fight

    Telecommunications firm Liberty Global wants another shot at showing the Tenth Circuit that it's entitled to a $2.4 billion deduction linked to transactions with foreign affiliates, claiming the court misapplied a rule that can disallow tax benefits from transactions that lack economic substance.

  • June 08, 2026

    Energy Transactions Atty Returns To McGuireWoods In SF

    A senior vice president with Aon's global mergers and acquisitions and transactions solutions team has rejoined McGuireWoods LLP as a partner in San Francisco, the firm announced Monday.

  • June 08, 2026

    Developers Stumped By Energy Credits' Foreign Debt Limits

    Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.

  • June 08, 2026

    McKesson Can't Defeat Valid Cost-Sharing Rules, Gov't Says

    The U.S. government urged a Texas federal court to uphold transfer pricing regulations that pharmaceutical giant McKesson is challenging in its push for a nearly $10 million tax refund, arguing the rules fall "well within the bounds" of the underlying statutory text.

  • June 06, 2026

    Inheritance Tax Penalties Surge By 35%, Data Shows

    Britain's tax authority imposed 35% more penalties for late inheritance tax returns in tax year 2024-25 compared with 2020-21, according to government data released by a law firm Saturday.

  • June 05, 2026

    Calif.'s Global Reporting Bill Could Embolden Other States

    A California bill that would require multinational corporations to report their global profits could spark similar legislation across the U.S. if lawmakers of revenue-hungry states perceive shortcomings in federal and international efforts to tackle profit shifting.

  • June 05, 2026

    11th Circ. Lets Man Fight $2.2M FBAR Penalties As Excessive

    A Georgia federal court correctly found that the owner of a sports equipment business willfully failed to disclose his foreign bank accounts, but it must give him a chance to challenge $2.2 million in resulting penalties as excessive under the Eighth Amendment, the Eleventh Circuit said.

  • June 05, 2026

    Abbott Says Timing Mismatch Lets $8B Gain Go Untaxed

    Abbott Laboratories asked the U.S. Tax Court to find that it needn't recognize an $8 billion gain in 2020 from transactions between several of its controlled foreign corporations because of a mismatch in the effective dates of different sections of the 2017 U.S. Tax Cuts and Jobs Act.

  • June 05, 2026

    HMRC's Reading Would Double-Tax £10M, Upper Tribunal Told

    Shareholders of a holding company argued before the Upper Tribunal on Friday that HM Revenue & Customs misinterpreted tax legislation, risking the same £10 million ($13.4 million) in payouts being taxed twice after a capital reduction.

  • June 05, 2026

    Taxation With Representation: Simpson Thacher, Fried Frank

    In this week's Taxation With Representation, Berkshire Hathaway Inc. takes Taylor Morrison Home Corp. private, global real estate investment company Kennedy Wilson forms a residential joint venture with Netherlands pension services provider APG, and Wellington Management acquires Hartford Funds from insurer The Hartford.

  • June 05, 2026

    Wife Of Bankrupt Former EY Tax Chief Sued By Trustees

    The bankruptcy trustees of former EY head of tax John Dixon are bringing a claim against his wife, according to a newly public entry on the High Court's filing system.

  • June 05, 2026

    Irish Presidency Outlines Forecast For EU Tax Info Shake-Up

    The incoming Irish presidency of the Council of the European Union outlined predictions for EU tax changes — including some related to information sharing — in a note to policy experts seen by Law360 on Friday.

  • June 04, 2026

    Feds Appeal Trade Court's Emergency Tariff Refund Order

    The federal government has appealed the U.S. Court of International Trade's order requiring refunds on all duties paid under the International Emergency Economic Powers Act after the U.S. Supreme Court struck them down this year, according to filings in the trade court and Federal Circuit.

  • June 04, 2026

    HMRC Defends Tax Win In £10M Share Payout Dispute

    The U.K.'s tax authority told a London court Thursday that a shareholder payout falls within anti-tax avoidance rules in a case concerning the tax treatment of £10 million ($13.4 million) in shares paid out following a capital reduction.

  • June 04, 2026

    Ex-Surgeon Agrees To $7.7M Tax Bill From Offshore Scheme

    A retired plastic surgeon reached a $7.7 million settlement with the federal government to resolve an Internal Revenue Service case alleging that he ran an offshore employee leasing scheme, according to an agreement filed in an Ohio federal court.

  • June 04, 2026

    EU Tobacco Tax Bill Dropped From Upcoming Negotiations

    Ambassadors from European Union countries failed to reach an agreement on a controversial EU tobacco taxation bill, according to an EU official, meaning the file has been withdrawn from the agenda of an upcoming meeting of member state finance ministers.

  • June 04, 2026

    EU Calls On Germany, Poland, Spain To Correct Tax Policies

    The European Union's executive branch has called on Germany, Poland and Spain to end tax policies that it has determined violate the bloc's rules.

  • June 04, 2026

    OECD Urges Nations to Mull Tax Breaks In Pillar 2 Safe Harbor

    Countries should "think carefully" about how their tax incentives will fit into a side-by-side safe harbor under the 15% global minimum corporate tax known as Pillar Two, the Organization for Economic Cooperation and Development said in a report released Thursday.

  • June 04, 2026

    HMRC Arrests Two Over Suspected £153M TikTok Tax Scam

    The tax authority said Thursday that it had arrested two men suspected of using TikTok to perpetrate an alleged multi-million-pound tax fraud by persuading users to hand over tax account details with the promise of "quick cash."

  • June 03, 2026

    Texas Instruments Defends Deductions For Exercised Options

    Texas Instruments challenged total deficiencies of $47.9 million for 2018 and 2019, much of it from the IRS' disallowance of deductions for deferred compensation, such as exercised stock options, under an approach consistent with a 2022 agency advice memorandum.

  • June 03, 2026

    UK Adults Unaware Of Inheritance Tax Relief, Insurer Says

    Almost three-quarters of British adults don't know that certain gifts are exempt from inheritance tax as the fiscal rules for estates and pensions are set to change in April 2027, according to research published Wednesday.

  • June 03, 2026

    USTR Floats Double-Digit Tariffs On Basis Of Forced Labor

    Sixty economies are facing added tariffs of either 10% or 12.5% on their exports to the U.S. following investigations by the U.S. Trade Representative's Office into countries' protections against the importing of goods produced with forced labor.

  • June 03, 2026

    Iran War Driving Slower Growth, Surging Inflation, OECD Says

    The Iran war is driving slower growth and surging inflation across the global economy, and U.S. tariff policy is adding to uncertainty, the OECD said Wednesday during a virtual news conference.

  • June 03, 2026

    USTR Seeks Input On China Preferential Trade Mechanism

    The Office of the U.S. Trade Representative announced what it is calling a government-to-government mechanism that will manage bilateral trade between the U.S. and China, including by considering tariff cuts, and asked for public comments on the program's development.

  • June 03, 2026

    Australia Considers Floating Tax Whistleblower Rewards

    The Australian Treasury is seeking feedback on its tax whistleblowing framework, including whether the regime should offer financial incentives for exposing misconduct and whether current rules effectively protect those who already do.

Expert Analysis

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

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    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

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    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.

  • Law School's Missed Lessons: Communicating With Clients

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    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.

  • Navigating Antitrust Risks When Responding To Tariffs

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    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.

  • Key Points From HMRC's Tax Reform Proposals

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    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.

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

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    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

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    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.

  • What To Note As UK Adopts OECD Crypto Disclosure Rules

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    With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.

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

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    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.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

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