International

  • August 17, 2026

    Split 10th Circ. Won't Revisit Liberty Global's $2.4B Tax Loss

    The Tenth Circuit said Monday it won't reconsider an April ruling against Liberty Global, upholding a decision that found the telecommunications giant improperly claimed a $2.4 billion deduction based on foreign transactions that lacked economic substance.

  • August 17, 2026

    Biz Pushes Class Cert. As Solution To IEEPA Refund Issues

    The U.S. Court of International Trade should grant class certification to companies seeking refunds of duties paid under the invalidated global tariff regime, the company serving as a test case for the refunds said in arguments mirroring those recently made in the underlying dispute.

  • August 17, 2026

    McKesson's $10M Tax Refund Bid Misreads Law, Gov't Says

    The U.S. government urged a Texas federal court to uphold transfer pricing regulations that McKesson is challenging in its push for a nearly $10 million tax refund, arguing the pharmaceutical giant has taken an overly narrow statutory reading.

  • August 17, 2026

    UnitedHealth Says IRS Seeking Transfer Pricing Adjustments

    The Internal Revenue Service has proposed transfer pricing adjustments for UnitedHealth Group Inc. that the company is disputing, according to a quarterly report.

  • August 17, 2026

    Atlassian Seeks To Reup Australia Advance Pricing Agreement

    Australian software company Atlassian Corp. is seeking to renew an advance pricing agreement with the Australian Taxation Office that produced a hefty settlement, the company said in its annual report.

  • August 14, 2026

    Meta's Litigation Distinct From Facebook's, IRS Says

    The case over Meta Platforms' 2017-2019 tax years is not identical to the one brought by its predecessor, Facebook, the IRS said in responding to Meta's claim that the government is seeking to relitigate the earlier dispute, which involved 2010.

  • August 14, 2026

    Rising Star: Baker McKenzie's Cameron Reilly

    Baker McKenzie partner Cameron Reilly helped secure a key tax court ruling for FedEx Corp. to invalidate regulations on mandatory repatriation under the 2017 federal tax changes, and was a lead attorney in Facebook Inc.'s successful challenge to cost-sharing regulations for multinational corporations, earning him a spot among the tax practitioners under 40 honored by Law360 as Rising Stars.

  • August 14, 2026

    UN Seeks Input On Draft Tax Convention And Protocols

    The United Nations is seeking input on a draft version of its proposed framework international tax convention, a protocol on taxing cross-border services and conventions on dispute prevention and resolution, the body's Department of Economic and Social Affairs said Friday.

  • August 14, 2026

    Taxation With Representation: Miller Thomson, Bennett Jones

    In this week's Taxation With Representation, GO Residential Real Estate Investment Trust and a consortium of buyers acquire H&R Real Estate Investment Trust, insurance exchange Accelerant goes private in a deal with Thoma Bravo, and Goldman Sachs acquires NEOS Investments.

  • August 14, 2026

    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.

  • August 14, 2026

    Coach Owner Reports $42M Global Min. Tax Bill In Singapore

    Tapestry, owner of the fashion brands Coach and Kate Spade, booked a $42.4 million charge for Singapore's qualified domestic minimum top-up tax in its latest annual report filed with the U.S. Securities and Exchange Commission.

  • August 14, 2026

    Cyberattack On French Tax Authority Exposes Data

    Data on individuals and businesses has been stolen in a cyberattack on France's tax authority, the country's Finance Ministry said.

  • August 14, 2026

    Maryland Tax Court Strikes Down Digital Advertising Tax

    Maryland's first-in-the-nation digital advertising tax violates the federal Internet Tax Freedom Act by applying only to electronic commerce, the state's tax court said in a group of decisions Friday, striking down the tax.

  • August 14, 2026

    Taxable Pension Withdrawals By Under-65s Reach £76B

    Britons under 65 have taken £75.5 billion ($102 billion) in taxable income from their pensions in just over a decade, an insurance technology company has said.

  • August 13, 2026

    Treasury Floats Foreign Currency Rules To Fix Timing Issues

    The U.S. Treasury Department proposed regulations Thursday that would smooth out timing wrinkles companies were facing when determining the taxable income of affiliates that conduct business in a foreign currency for 2025 returns.

  • August 13, 2026

    Africa Wants Precedence For UN Tax Pact's Dispute Protocol

    The 54-member African Group wants the United Nations tax convention's dispute protocol to supersede substantially similar mechanisms already in force unless parties agree otherwise, according to negotiations held Thursday.

  • August 13, 2026

    Rising Star: Covington's Brian Harris

    Brian Harris of Covington & Burling LLP represented companies from the world of biomedicine, retail and even sports after advising on the acquisition and relocation of the NHL's Arizona Coyotes in transactional tax matters, earning him a spot as one of the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • August 13, 2026

    EU Rebuts US Claim That Carbon Levy Resembles Tariffs

    The European Commission rejected a claim Thursday that the bloc's carbon import levy resembles tariffs imposed by the U.S. on steel and aluminum, responding to statements by the U.S. ambassador to the European Union.

  • August 12, 2026

    Rising Star: Cleary's Kylie Barza

    Kylie Barza of Cleary Gottlieb Steen & Hamilton LLP has advised on several billion-dollar transactions, including Alphabet's $4.75 billion acquisition of Intersect Power, which closed in 2026, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • August 12, 2026

    Nations Want AI Covered In UN Tax Pact's Services Protocol

    Nations want artificial intelligence covered in a protocol on cross-border services under the proposed United Nations Framework Convention on International Tax Cooperation, according to negotiations.

  • August 12, 2026

    USCIB Urges OECD To Broaden Digital Platform Tax Relief

    The Organization for Economic Cooperation and Development should expand its proposed threshold for triggering digital platform reporting obligations to include all relevant services that fall below a minimum amount, the U.S. Council for International Business said Wednesday.

  • August 12, 2026

    New UK Digital Tax Filing Sees First Wave Of Uptake

    More than 436,000 sole traders and landlords have successfully submitted a digital income tax filing that became required in the U.K. this year, HM Revenue & Customs said Wednesday.

  • August 12, 2026

    Italian Deputy PM Proposes New Tax On Bank Profits

    Italy's deputy prime minister has called for a three-year tax contribution from the country's top 10 banks to boost revenues for the 2027 budget.

  • August 11, 2026

    Nations Concerned By Nexus For Service Fees In UN Tax Pact

    Some nations expressed concern that overlapping claims to source-taxation rights could arise under the nexus rules within the United Nations framework tax convention's draft protocol on cross-border services, according to negotiations Tuesday.

  • August 11, 2026

    Fed. Circ. Says Brick Duty Lacks Definition, Offers Alternative

    The U.S. Court of International Trade properly found that duty orders on certain heat-resistant bricks lack specific chemical makeup parameters, offering a broad exclusion for one type of brick that may be better challenged with a circumvention proceeding, a Federal Circuit panel ruled Tuesday.

Expert Analysis

  • Rule Amendments Pave Path For A Privilege Claim 'Offensive'

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    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.

  • Litigation Funding Could Create Ethics Issues For Attorneys

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    A litigation investor’s recent complaint claiming a New York mass torts lawyer effectively ran a Ponzi scheme illustrates how litigation funding arrangements can subject attorneys to legal ethics dilemmas and potential liability, so engagement letters must have very clear terms, says Matthew Feinberg at Goldberg Segalla.

  • E-Discovery Quarterly: Recent Rulings On Dynamic Databases

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    Several recent federal court decisions illustrate how parties continue to grapple with the discovery of data in dynamic databases, so counsel involved in these disputes must consider how structured data should be produced consistent with the requirements of the Federal Rules of Civil Procedure, say attorneys at Sidley.

  • Defeating Estoppel-Based Claims In Legal Malpractice Actions

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    State supreme court cases from recent years have addressed whether positions taken by attorneys in an underlying lawsuit can be used against them in a subsequent legal malpractice action, providing a foundation to defeat ex-clients’ estoppel claims, says Christopher Blazejewski at Sherin and Lodgen.

  • The Biz Court Digest: How It Works In Massachusetts

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    Since its founding in 2000, the Massachusetts Business Litigation Session's expertise, procedural flexibility and litigant-friendly case management practices have contributed to the development of a robust body of commercial jurisprudence, say James Donnelly at Mirick O’Connell, Felicia Ellsworth at WilmerHale and Lisa Wood at Foley Hoag.

  • Why Appellees Should Write Their Answering Brief First

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    Though counterintuitive, appellees should consider writing their answering briefs before they’ve ever seen their opponent’s opening brief, as this practice confers numerous benefits related to argument structure, time pressures and workflow, says Joshua Sohn at the U.S. Department of Justice.

  • Attys Beware: Generative AI Can Also Hallucinate Metadata

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    In addition to the well-known problem of AI-generated hallucinations in legal documents, AI tools can also hallucinate metadata — threatening the integrity of discovery, the reliability of evidence and the ability to definitively identify the provenance of electronic documents, say attorneys at Law & Forensics.

  • When Atty Ethics Violations Give Rise To Causes Of Action

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    Though the Model Rules of Professional Conduct make clear that a violation of the rules does not automatically create a cause of action, attorneys should beware of a few scenarios in which they could face lawsuits for ethical lapses, says Brian Faughnan at Faughnan Law.

  • Law School's Missed Lessons: Educating Your Community

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    Nearly two decades prosecuting scammers and elder fraud taught me that proactively educating the public about the risks they face and the rights they possess is essential to building trust within our communities, empowering otherwise vulnerable citizens and preventing wrongdoers from gaining a foothold, says Roger Handberg at GrayRobinson.

  • 5 Crisis Lawyering Skills For An Age Of Uncertainty

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    As attorneys increasingly face unprecedented and pervasive situations — from prosecutions of law enforcement officials to executive orders targeting law firms — they must develop several essential competencies of effective crisis lawyering, says Ray Brescia at Albany Law School.

  • It's Time For The Judiciary To Fix Its Cybersecurity Problem

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    After recent reports that hackers have once again infiltrated federal courts’ electronic case management systems, the judiciary should strengthen its cybersecurity practices in line with executive branch standards, outlining clear roles and responsibilities for execution, says Ilona Cohen at HackerOne.

  • Rules Of Origin Revamp May Be Next Big Trade Development

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    The rules of origin for determining what tariff applies to any given import appear to be on the cusp of an important rethink, and it seems likely that the administration will try to align the rule with its overall tariff strategy in one of three ways, says Ted Posner at Baker Botts.

  • SDNY OpenAI Order Clarifies Preservation Standards For AI

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    The Southern District of New York’s recent order in the OpenAI copyright infringement litigation, denying discovery of The New York Times' artificial intelligence technology use, clarifies that traditional preservation benchmarks apply to AI content, relieving organizations from using a “keep everything” approach, says Philip Favro at Favro Law.

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