International
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September 21, 2026
IRS Again Delaying Dividend Anti-Abuse Regs
The IRS is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, the agency announced Monday.
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September 21, 2026
Varian, Gov't Appeal Foreign Dividend Decision To 9th Circ.
Varian Medical Systems Inc. is appealing a U.S. Tax Court decision that it owes more than $7.2 million to the Internal Revenue Service as a result of the court limiting its deemed dividends deduction, while the government is also appealing, according to filings in the Ninth Circuit.
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September 21, 2026
Canadian Man Owes Tax As Homebuilder, Court Says
A Canadian man owes about CA$540,000 ($385,200) in sales tax as the builder of a home sold for a profit despite claiming that his original motivation was to live in the home, the Tax Court of Canada found.
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September 21, 2026
IRS Asks 5th Circ. To Pause Microcaptive Rules Case
The IRS asked the Fifth Circuit to stay briefing in a global tax services provider's bid to revive its challenge to the agency's reporting rules for microcaptive insurance companies pending the resolution of a related case before the appeals court.
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September 21, 2026
Housing Lender Calls On UK To Ditch Building Safety Tax
The U.K. government should scrap its incoming building safety levy to reduce barriers to constructing new houses as part of its autumn budget, a property lender urged Monday.
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September 21, 2026
Funder Says $13M Albania Default Judgment Should Stand
Litigation funder Omni Bridgeway has urged a D.C. federal court to preserve a default judgment enforcing a roughly $13 million arbitral award against Albanian state entities, arguing they waited an unreasonable 18 months to appear despite receiving repeated notice of the case.
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September 21, 2026
New EU Customs Rules Kick In Amid E-Commerce Boom
A fresh set of European Union customs rules entered into force Monday to address new trade challenges, including the rapid expansion of e-commerce.
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September 18, 2026
House Bill Would Limit BEAT, Make Other Int'l Tax Changes
The U.S. would limit the scope of its base erosion and anti-abuse tax and modify several other international tax measures under a bill introduced by a Republican on the House Ways and Means Committee.
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September 18, 2026
Tax Tipster Fights For Whistleblower Award At DC Circ.
U.S. Tax Court wrongly upheld the IRS denying a whistleblower award for information about a taxpayer's transfer pricing despite the agency failing to follow its internal procedures, the individual told the D.C. appeals court.
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September 18, 2026
Taxation With Representation: Davis Polk, Latham, Sullivan
In this week's Taxation With Representation, a group backed by Michael Dell's family office and Sequence Holdings acquires a majority interest in The Baldwin Group, May Mobility merges with a blank check company, and Infineon Technologies sells its memory chip business to Winbond Electronics.
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September 18, 2026
IRS Floats Tax Return Form With Question About Citizenship
The Internal Revenue Service released a draft version of the Form 1040 individual tax return that for the first time would include a question about the filer's citizenship status.
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September 18, 2026
Five Deny Tax Fraud Charges Over Payroll Outsourcing
Five individuals pleaded not guilty Friday at a London criminal court to tax fraud and money laundering charges linked to an HM Revenue and Customs investigation into a payroll outsourcing business.
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September 17, 2026
IRS Defends Regs In Meta's Fight Against $16B Tax Bill
The IRS urged the U.S. Tax Court to validate regulations that Facebook parent Meta is challenging in its fight against a nearly $16 billion tax bill, arguing that the social media giant is recycling arguments the Ninth Circuit already rejected.
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September 17, 2026
IRS Properly Nixed Whistleblower's Award Bid, Tax Court Says
The IRS didn't abuse its discretion in denying a whistleblower's bid for an award for information regarding alleged underpayments by a large multinational corporation, the U.S. Tax Court ruled Thursday, upholding the agency's determination that it had already identified the key issues for its investigation.
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September 17, 2026
Electricity Tax Rules Kept In Irish EU Reg Draft, Over Protests
The Irish government, currently leading the Council of the European Union, kept rules requiring tax rates on electricity to be no less favorable than those on natural gas in its revision of a draft EU regulation, despite some member states' objections, according to a document obtained Thursday by Law360.
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September 17, 2026
6 Convicted In €520M Mafia-Linked VAT Fraud Syndicate
A Milan court convicted six individuals of participating in a €520 million ($597 million) value-added tax fraud scheme involving electronics that was bankrolled by an Italian crime syndicate, the European Public Prosecutor's Office said Thursday.
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September 17, 2026
Canada Tax Court Limits Deductions Under Insurance Policy
Two brothers who run a Canadian agricultural machinery manufacturing business recently lost their dispute with federal revenue collectors after the Tax Court of Canada limited their attempt to claim millions in tax deductions through a complex life insurance arrangement.
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September 17, 2026
UK Film Tax Relief Rises Past £700M
The U.K. government paid out £702 million ($937 million) in a tax relief program for the film industry in the 2024-25 tax year, an increase of 39% from the previous year, according to official data published Thursday.
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September 17, 2026
HMRC Draft Rules Set 22% Charge On Cash In Stock ISAs
Britain's tax authority published draft rules Thursday for the 2027 cash limit for individual savings accounts, including a new flat-rate charge of 22% on interest earned on cash parked inside stocks and shares wrappers.
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September 17, 2026
Australian Tax Office Takes In $1.3B From Corp. Settlements
The Australian Taxation Office collected AU$1.3 billion ($925 million) in revenue from settlements with large corporations during the most recent tax year, representing 58% of the total disputed amount, the agency said Thursday.
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September 17, 2026
4 Arrested In €15.7M Phone Tax Fraud, EU Says
European authorities conducted searches, arrests and asset freezes as part of an investigation into a suspected cross-border value-added tax fraud involving online mobile phones sales, prosecutors said Thursday.
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September 17, 2026
UK Think Tank Urges New Taxing Powers For Growth
The Labour government should allow mayors to keep a greater share of corporate and income tax revenue to promote economic growth across the U.K., a think tank urged in a new report.
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September 16, 2026
House Clears Russia Sanctions Bill With New Tariff Powers
The U.S. House of Representatives approved legislation Wednesday that would enhance President Donald Trump's economic tools to pressure Russia and Iran, including new tariff authorities to impose duties on imports from countries found to economically support Russia, sending the bill to his desk.
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September 16, 2026
10th Circ. Mulls Audit Law In $16M Buy.com Founder Tax Suit
A Tenth Circuit panel grappled with whether a statutory auditing regime for partnerships allowed the founder of now-defunct Buy.com to challenge the validity of an audit extension agreement with the IRS during his personal tax proceedings.
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September 16, 2026
Perrigo Shifted $212M In Profits To Shell Co., US Tells 6th Circ.
A Michigan court errantly allowed pharmaceutical giant Perrigo to avoid taxes on $212 million in profits by assigning a lucrative contract to a shell company that played no economic role in fulfilling its terms, the government told the Sixth Circuit.
IRS Can Enforce Summons In Korean Probe Of VC Partner
The IRS can enforce a summons seeking bank information about a venture capitalist on behalf of South Korean tax authorities, a California federal judge ruled, holding that the statutory requirement to provide advance notice applies only to domestic tax liabilities.
Exxon Wins $456M Tax, Penalty Refund In Qatar Gas Case
Exxon is entitled to a $274 million tax refund for a deduction of interest expenses fully allocated to the company by its partnership with Qatar to extract natural gas, a Texas federal court said Friday in an order that indicated $182 million in penalties should be returned as well.
Addison Lee Founder Loses £20M Appeal Over Tax Status
A businessman who founded British private car hire company Addison Lee can't avoid over £20.5 million ($27.4 million) in taxes after a London tribunal rejected his claim to nondomicile tax status over his family connections to Ireland.
IRS Can Enforce Summons In Korean Probe Of VC Partner
The IRS can enforce a summons seeking bank information about a venture capitalist on behalf of South Korean tax authorities, a California federal judge ruled, holding that the statutory requirement to provide advance notice applies only to domestic tax liabilities.
Exxon Wins $456M Tax, Penalty Refund In Qatar Gas Case
Exxon is entitled to a $274 million tax refund for a deduction of interest expenses fully allocated to the company by its partnership with Qatar to extract natural gas, a Texas federal court said Friday in an order that indicated $182 million in penalties should be returned as well.
Addison Lee Founder Loses £20M Appeal Over Tax Status
A businessman who founded British private car hire company Addison Lee can't avoid over £20.5 million ($27.4 million) in taxes after a London tribunal rejected his claim to nondomicile tax status over his family connections to Ireland.
Featured Stories
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Reporting Prediction Market Wins A Safe Bet Amid IRS Silence
The IRS has yet to clarify how it will treat money people pocket from trading event contracts on prediction market platforms, but specialists urge against taking the agency's silence as an excuse to omit wins and losses from returns.
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China's Tax Changes Leave Rich Rethinking Wealth Planning
Changes to China's tax treatment of offshore trusts and a wider compliance cleanup have prompted wealthy investors to rethink strategies designed to lower their tax burdens, experts say.
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Int'l Tax In July: New UK PM, Win For Denmark, US Tariff Pivot
New leadership in the U.K. comes with the possibility of higher tax rates for some businesses in light of Prime Minister Andy Burnham's plans to reform the country's healthcare system, while a recent U.K. Supreme Court case could spell good news for Denmark in its long-running battle against cum-ex fraud. Here, Law360 looks at some of July's biggest international tax developments.
Expert Analysis
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Attorneys Using AI May Have Ethical Duty To Redact Docs
The trajectory of legal ethics guidance in recent years strongly suggests that as redaction technology becomes more accessible, the failure to use it when uploading highly confidential materials into artificial intelligence tools will become increasingly difficult to defend as reasonable, say attorneys at Lewis Brisbois.
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Md. Court Got Ad Tax Similarity Analysis Wrong
Decisions striking Maryland’s digital advertising tax are fundamentally flawed because the Maryland Tax Court found similarity between digital ads and other ads without considering deep market distinctions, says Darien Shanske at UC Davis School of Law.
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Taekwondo Makes Me A Better Lawyer
Taekwondo has taught me to recognize when to fight for a position and when to focus on finding a solution, and that the best outcomes are often achieved by solving problems — all of which has improved my work as a bankruptcy lawyer, mediator and Subchapter V trustee, says Amy Denton Mayer at Berger Singerman.
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OECD Draft Could Guide Pricing For Intragroup R&D Deals
The Organization for Economic Cooperation and Development's proposed revisions to its intragroup transfer pricing guidelines provide helpful tips for determining the cost base for contract research and development services, highlighting the importance of selecting a reasonable set of third-party comparables and appropriate means for evaluating markups, says economist Harold McClure.
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Monitor Exposure, Stay Flexible Amid Tariff Uncertainty
To navigate an unstable trade environment, businesses must evaluate their exposure to new tariffs invoked under a patchwork of statutory authorities and be prepared to adapt to further changes that may be on the horizon, says Bhargav Prajapati at Capital Trade.
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Being In A Band Made Me A Better Lawyer
Playing shows in storied New York City venues and rehearsing with my bandmates in poorly ventilated rooms helped develop the professional qualities I rely on as a litigator, including an ability to collaborate with strong-minded equals and the determination to treat each client with singular focus, says Eliad Shapiro at Herrick Feinstein.
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The Divergent Approaches In US, EU Forced Labor Standards
Forced labor guidance documents recently issued by the U.S. and the European Union have meaningful differences, with the U.S. taking a documentary approach to compliance and the EU emphasizing human rights risks as a governance challenge, but one model will likely exert greater influence, say attorneys at Steptoe.
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Going To Hardcore Shows Makes Me A Better Lawyer
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While government contracts law and the hardcore scene may seem entirely unrelated, in my experience, both are about community, focus, being prepared for the unexpected and managing chaos, says Isaac Natter at Fluet.
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Handling Section 301 Tariffs When CBP Detains Goods
Importers subject to Section 301 tariffs on goods under a U.S. Customs and Border Protection forced labor hold should consider three approaches when deciding whether to pay tariffs on goods that may ultimately be excluded, or wait and watch port demurrage compound daily, says James Ferry at Ferry Trade.
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Judges On AI: Examining Administrative, Organizational Uses
U.S. District Judge Alan Albright of the Western District of Texas examines how artificial intelligence could transform a court's ability to deal with administrative work and organize materials when preparing for hearings or drafting opinions, thereby affording judges more time to resolve contested issues.
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Being A Magician Makes Me A Better Lawyer
The skills I've developed as a lifelong magician have translated directly into tangible benefits in the courtroom because performing magic and trying cases both live at the intersection of psychology, storytelling, timing and disciplined rehearsal, says Mark Dombroff at Fox Rothschild.
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Choral Singing Makes Me A Better Lawyer
Singing in the New York City Bar Chorus — a hobby partly inspired by the late U.S. District Judge Richard Owen, who infused my clerkship year with opera music — has improved my legal career by refining my abilities to listen, exude confidence and develop emotional intelligence, says Bonnie Baker at Friedman Kaplan.
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Power To The Paralegals: Burnout As A Structural Problem
Law firm leadership can best retain their paralegals not by encouraging self-care, but by seeking top-down structural solutions for the quiet proliferation of responsibilities and the vicarious exposure to client trauma that particularly drive burnout in this vital role, says Erika Sneeringer at Brockstedt Mandalas.