International

  • July 17, 2026

    EU Countries Split On Pillar 2 Multinationals' Reporting Breaks

    European Union countries are deeply divided on proposals from the European Commission to exempt Pillar 2 companies from certain rules that aim to prevent tax abuse, EU officials told Law360.

  • July 16, 2026

    Tile Importer Adds To Tax Dispute Over Captive Arrangement

    A New York glass tile importer that had challenged IRS income adjustments of $4.8 million for 2018 through 2020 related to its captive insurance program added a fourth year to its dispute, saying the agency erred in increasing its income by $1.2 million for 2021.

  • July 16, 2026

    Meta Says Altera Ruling Doesn't Control In Stock Option Fight

    The Ninth Circuit's 2019 ruling against Altera, which upheld an IRS regulation requiring companies to share the cost of stock options in joint ventures with foreign affiliates, has no bearing on Meta Platforms' dispute over the same issue, the social media company told the U.S. Tax Court.

  • July 16, 2026

    German Court Convicts Former Banker In €320M Cum-Ex Case

    A former banker at an Australian firm was convicted Thursday by a German court of attempting €320 million ($366 million) in tax evasion as part of a cum-ex dividend scandal, a court spokesperson told Law360.

  • July 16, 2026

    Ashurst Perkins Adds Tax Pro In LA From Stradling Yocca

    Ashurst Perkins Coie announced Thursday that it has bolstered its tax practice with a Los Angeles-based partner who came aboard from Stradling Yocca Carlson & Rauth PC.

  • July 16, 2026

    HMRC Seeks Input On Reworking Bank Levy Definitions

    HM Revenue & Customs is seeking input on changing some of the definitions of terms in the U.K.'s bank levy legislation because of changes to the provisions they reference, according to a consultation launched Thursday.

  • July 16, 2026

    USTR Broadens Exemptions Ahead Of 25% Brazil Tariff

    A 25% tariff on Brazilian goods will begin next week with an expanded exemption list following public comments on the action, U.S. Trade Representative Jamieson Greer announced.

  • July 16, 2026

    Belgian Energy Revenue Cap Is Lawful, EU Court Adviser Says

    An adviser to the European Union's top court backed Belgium's application of a bloc-wide mechanism for capping revenue collected by certain energy companies, concluding Thursday that the levy didn't deviate from EU law despite applying at a lower threshold.

  • July 16, 2026

    HMRC Resists Port Co.'s Claim To Broader Tax Allowances

    HM Revenue & Customs pushed back Thursday against Liverpool's port operator over its claims that the construction costs of a quay wall qualify for capital allowances, arguing before the Upper Tribunal that the use of the structure to mount cranes doesn't entitle it to such tax breaks.

  • July 16, 2026

    Frozen Thresholds Drag 10M UK Pensioners Into Paying Tax

    The number of U.K. pensioners paying income tax has risen by three million in the five years since earning thresholds were frozen, government figures have revealed.

  • July 16, 2026

    HMRC Seeks Retrial After Hung Jury In Tax KC Evasion Case

    A judge discharged jurors on Thursday in HM Revenue and Customs' prosecution of a barrister for tax evasion after almost two weeks of deliberations in which the panel was unable to reach a verdict.

  • July 15, 2026

    Circuit-By-Circuit Guide To The US Supreme Court's Term

    Federal appeals courts had wide-ranging successes and struggles during the U.S. Supreme Court's recently completed term: One had its best showing in years following its worst showing in years; one felt déjà vu after recently starting to find favor with the justices; and one saw its reputation for independence occupy a rare role in the Supreme Court spotlight.

  • July 15, 2026

    Eaton Says IRS Position Turns 'Arm's Length' On Its Head

    The IRS' argument in support of its income allocations to Eaton Corp. from an Irish affiliate effectively inverts the arm's-length standard underlying U.S. transfer pricing law, seeking to price transactions between related companies by assuming non-arm's-length behavior, the company told the U.S. Tax Court.

  • July 15, 2026

    CIT Judge Says Order Incoming For Next Tariff Refund Phase

    The U.S. Court of International Trade judge overseeing U.S. Customs and Border Protection's development of a duty refund system for tariffs struck down by the U.S. Supreme Court forecast new directions for the government as it prepares another phase of its tariff refund system, according to an order published Wednesday.

  • July 15, 2026

    Siemens Wins Tax Deduction In IRS Rules Mismatch Case

    Siemens Medical Solutions is allowed the full dividends-received deduction it claimed for 2019, the U.S. Tax Court held Wednesday, throwing out an IRS regulation that attempted to reduce the deduction by aligning the effective date of different provisions under 2017 tax legislation.

  • July 15, 2026

    HMRC Still Weighing How To Treat Offshore Interest Income

    There's a general consensus that the United Kingdom's tax system creates difficulties for taxpayers with offshore interest income, but there are differing views on how to tackle the issue, so no fixes are being proposed for now, HM Revenue & Customs said Wednesday in summarizing a consultation.

  • July 15, 2026

    Energy Tax Applies To Propane Used For Tests, EU Court Says

    The European Union's energy tax directive applies to propane used by a German company to test gas turbine burners, even though it wasn't burning the propane to generate heat per se except to test the burners, the European General Court said Wednesday.

  • July 15, 2026

    Port Co. Defends Tax Claim On £57M Project At Upper Tribunal

    Liverpool's port operator defended its claim at the Upper Tribunal on Wednesday to tax allowances on more than £57 million ($76.3 million) in construction costs after Britain's tax authority argued that the project didn't qualify for the tax breaks.

  • July 15, 2026

    Russia Sanctions Bill Goes Too Far On Tariff Power, Dems Say

    A reworked version of a bipartisan bill aimed at sanctioning Russia over the war in Ukraine wrongly places too much tariff power in the hands of President Donald Trump, some leading congressional Democrats said.

  • July 15, 2026

    Pillar 2 Revenue Intake Falls Short Of Predictions, OECD Says

    The worldwide corporate 15% minimum tax agreement known as Pillar Two has so far brought in less revenue than expected, the Organization for Economic Cooperation and Development said Wednesday.

  • July 15, 2026

    EU Court Says Danish VAT Rule Must Truly Target Tax Evasion

    Denmark can set a 100% minimum ownership threshold for businesses wishing to form a VAT group only if national courts deem the requirement necessary and proportionate for combating tax abuse, a European Union court said Wednesday.

  • July 14, 2026

    Bike Seller Says IRS' Undervaluation Caused $3M Deficiency

    A California bicycle seller told the U.S. Tax Court that the IRS' faulty appraisal of its value caused the agency to mischaracterize a transaction with its parent company as a discharge of indebtedness and a $15.5 million income increase, leading to a $3.3 million deficiency assessment.

  • July 14, 2026

    IRS Ethics Guidance Highlights AI Billing Tensions

    Recent IRS ethics guidance urged attorneys to acknowledge the time-saving features of artificial intelligence when billing clients, underlining the legal industry's ongoing reckoning with how, or if, this technology fits into the traditional practice of charging by the hour.

  • July 14, 2026

    Port Co. Can't Claim Tax Breaks On £57M, Tribunal Told

    A London tribunal was wrong to rule that Liverpool's port operator can claim tax allowances on £57.1 million ($76.4 million) spent constructing part of a deep-water container terminal, the U.K. tax authority argued Tuesday.

  • July 14, 2026

    US Refunded $49.2B In Tariffs Last Month, Treasury Says

    The U.S. government issued tariff refunds totaling more than $49.2 billion in June, dragging down customs duties to account for a monthly net loss of $25.5 billion in the federal accounts, according to the U.S. Department of the Treasury.

Expert Analysis

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

    Author Photo

    As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.

  • Opportunity Zone's Future Corp. Tax Benefits Still Uncertain

    Author Photo

    Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.

  • How GILTI Reform Affects M&A Golden Parachute Planning

    Author Photo

    Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.

  • Demystifying The Civil Procedure Rules Amendment Process

    Author Photo

    Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.

  • Parenting Skills That Can Help Lawyers Thrive Professionally

    Author Photo

    As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.

  • Trump Tax Law's Most Impactful Energy Changes

    Author Photo

    The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.

  • Adapting To Private Practice: From Texas AUSA To BigLaw

    Author Photo

    As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.

  • Advice For 1st-Gen Lawyers Entering The Legal Profession

    Author Photo

    Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.

  • Trump Tax Law's Most Impactful Corp. And Individual Changes

    Author Photo

    The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.

  • From Clerkship To Law Firm: 5 Transition Tips For Associates

    Excerpt from Practical Guidance
    Author Photo

    Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.

  • Trump Tax Law's Most Consequential International Changes

    Author Photo

    The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.

  • Associates Can Earn Credibility By Investing In Relationships

    Author Photo

    As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.

  • Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling

    Author Photo

    The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.