International

  • January 03, 2025

    Germany Suspends Tax Treaty With Belarus

    The German government suspended its treaty to avoid double taxation with Belarus as of the new year following Belarus' move to suspend portions of the agreement in June, the German Federal Ministry of Finance said.

  • January 03, 2025

    UK Levy Hike Drives Labor Costs Up In 2025, Think Tank Says

    U.K. businesses are facing a spike in labor costs, thanks to the government's decision to raise employers' National Insurance contributions, a payroll levy used to fund social programs, a think tank said Friday.

  • January 02, 2025

    Japanese Cabinet Approves Backstop To 15% Min. Tax

    Japan's Cabinet approved a backstop to its 15% global minimum tax that would enable authorities to collect on multinational corporations' profits in foreign jurisdictions taxed below the minimum rate, according to the country's Ministry of Finance.

  • January 02, 2025

    Republicans Want Yellen To Answer For Chinese Cyberattack

    Congressional Republicans want U.S. Treasury Secretary Janet Yellen to explain how a Chinese state-sponsored entity hacked into Treasury's computer systems and accessed potentially sensitive information.

  • January 02, 2025

    NJ Residents Freed Of $2.1M Tax Bill On Repatriated Income

    Two New Jersey residents don't owe state tax on income repatriated under the 2017 federal tax overhaul, the state's tax court ruled, saying New Jersey's personal income tax laws don't include deemed dividends as a category of taxable income.

  • January 02, 2025

    Feds Ask High Court To Unpause Corporate Transparency Law

    The federal government is asking the U.S. Supreme Court to lift a Texas judge's injunction against the Corporate Transparency Act, telling the justices in a new application that the 2021 anti-money laundering law's compliance deadlines should take effect while the Fifth Circuit hears the full case.

  • January 02, 2025

    IRS, Treasury Float Regs On Excise Taxes For Drugmakers

    The IRS and Treasury proposed rules for charging excise taxes to drugmakers that refuse to negotiate drug prices with Medicare under requirements of the 2022 tax and climate law, saying the tax only would apply to manufacturers and importers that initially sell the drugs.

  • January 02, 2025

    Consolidated Return Regs Revised With Gender-Neutral Terms

    The IRS and Treasury finalized rules for companies that file consolidated federal income tax returns, saying the new regulations provide needed modernizations to terminology, including removing gender-specific pronouns.

  • January 01, 2025

    US International Tax Issues to Watch In 2025

    As President-elect Donald Trump and Republicans take control of the U.S. government in 2025, policymakers are expected to address changing international provisions in the Internal Revenue Code and reevaluate the country's role in global tax talks. Here, Law360 examines key U.S. international tax policy issues to watch in the new year.

  • January 01, 2025

    Federal Tax Policy To Watch In 2025

    While Republicans will hold majorities in both chambers of Congress in 2025, internal party divisions and procedural hurdles could complicate the GOP's effort to renew its 2017 tax overhaul law. Here, Law360 details federal tax policy to watch this year.

  • January 01, 2025

    Top International Tax Cases To Watch In 2025

    Major multinational corporations such as 3M and Coca-Cola will continue to litigate high-stakes international tax cases during 2025, including transfer pricing disputes with billions of dollars on the line and fights against regulations that allegedly exceed the government's authority. Here, Law360 looks at six key international tax cases to follow in the new year.

  • January 01, 2025

    European Tax Policy To Watch In 2025

    The European Union may have to go it alone on international tax policy in 2025, especially because President-elect Donald Trump's return to power means the U.S. will likely oppose any multilateral solution to taxing the digital economy. Here, Law360 looks at important European tax developments to watch for this year.

  • January 01, 2025

    Top Federal Tax Cases To Watch In 2025

    Over the next year, tax practitioners will be closely monitoring suits that challenge the IRS' use of the economic substance doctrine, take advantage of the U.S. Supreme Court's landmark decision curbing federal agencies' regulatory authority and dispute the government's handling of worker retention credits. Here, Law360 looks at key federal tax cases to follow in 2025.

  • December 23, 2024

    Anti-Laundering Law Is Likely Constitutional, 5th Circ. Rules

    The Fifth Circuit on Monday lifted a lower court's nationwide block of a federal corporate transparency law, ruling in an unpublished order that the federal government made a "strong showing" that it could successfully defend the law's constitutionality.

  • December 20, 2024

    Utah Judge Pauses Challenge To Corporate Transparency Act

    A Utah federal judge has stayed a case seeking to block the Corporate Transparency Act to see how the new administration of President-elect Donald Trump handles the law after a kindred case in Texas won a preliminary injunction on it.

  • December 20, 2024

    Rules On Earnings, Profits Still Being Vetted, IRS Official Says

    Recently proposed rules for previously taxed earnings and profits aren't able to be relied on by taxpayers until they are finalized because they contain new approaches that have to be properly vetted through a notice and comment period, an IRS official said Friday.

  • December 20, 2024

    Top Federal Tax Decisions Of 2024

    Over the past year, federal courts have issued decisions further delimiting the power of the Internal Revenue Service, with the First Circuit affirming a decision to allow agency summonses for cryptocurrency account records and an Arizona federal court rejecting a call to lift the agency's moratorium on processing pandemic-era worker credits. Here, Law360 reviews some of the most significant federal tax decisions of 2024.

  • December 20, 2024

    Digital Taxes In Flux Amid Renewed US Tariff Threats

    Governments around the world revisited their approaches to digital services taxes this year by adopting broader versions, raising rates, carving out industries and analyzing the impacts of adopting unilateral measures as threats of U.S. tariffs materialize once again. Here, Law360 looks at how countries around the world are considering, adopting or changing their DSTs.

  • December 20, 2024

    Osborne Clarke Pro Fined £50K Over Zahawi Libel Letter

    A tribunal fined an Osborne Clarke LLP partner who represented Nadhim Zahawi £50,000 ($62,700) on Friday for trying to stop a blogger revealing that the former chancellor was contemplating libel action over allegations of dishonesty in his tax affairs.

  • December 19, 2024

    Atty Exits Denmark's $2.1B Tax Fraud Case After Settlement

    A New York federal court removed an attorney from a $2.1 billion tax fraud suit after Denmark's tax authority settled with him on his involvement in the matter, according to recent filings.

  • December 19, 2024

    Denmark Says $500M Recovered In Dividend Tax Fraud Suits

    Denmark's tax administration has recovered a total of 3.6 billion Danish kroner ($500 million) in money lost to suspected dividend tax refund fraud after entering settlements of civil cases in several countries in 2024, Denmark's tax minister announced.

  • December 19, 2024

    5th Circ. Urged To Deny Tax Break For Doc's Captive Insurance

    A physician who owns a network of urgent care clinics was correctly denied tax deductions along with his wife for over $1 million in premiums they paid to insurance companies they owned, the government told the Fifth Circuit, saying the captive arrangements didn't qualify as insurance for tax purposes.

  • December 19, 2024

    UK Adds Pillar 2 Backstop To Finance Bill

    The U.K. government introduced amendments to its latest finance bill Thursday that would update its Pillar Two global minimum tax system and add the backstop to the regime known as the undertaxed profits rule.

  • December 18, 2024

    Skat Fights To Bring New Cum-Ex Fraud Case Against Broker

    The Danish tax authority argued at a London appeals court on Wednesday that it should not be blocked from bringing fresh tax fraud claims against an English brokerage, contending that the claims cover new material not already decided in earlier proceedings.

  • December 18, 2024

    Morrison Foerster Cites Tariffs As Key M&A Variable For 2025

    International law firm Morrison Foerster LLP is among those citing President-elect Donald Trump's tariff plans as a key wild card that could affect mergers and acquisitions deal flow in 2025, a Wednesday report from the firm shows. 

Expert Analysis

  • Congress Can And Must Enact A Supreme Court Ethics Code

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    As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.

  • What To Make Of Dueling Corporate Transparency Act Rulings

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    Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.

  • The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan

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    Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.

  • State Of The States' AI Legal Ethics Landscape

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    Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.

  • 8 Childhood Lessons That Can Help You Be A Better Attorney

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    A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.

  • This Election, We Need To Talk About Court Process

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    In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.

  • Mental Health First Aid: A Brief Primer For Attorneys

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    Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.

  • The Trade And Tax Issues Behind US-Canada Digital Tax Clash

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    The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.

  • Litigation Inspiration: Honoring Your Learned Profession

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    About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.

  • AI May Limit Key Learning Opportunities For Young Attorneys

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    The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.

  • Ruling On Foreign Dividend Break Offers 2 Tax Court Insights

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    In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.

  • Why Now Is The Time For Law Firms To Hire Lateral Partners

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    Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • Considering Possible PR Risks Of Certain Legal Tactics

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    Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.

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