International

  • 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.

  • July 14, 2026

    3 Convicted In €50M German VAT Fraud With Cars, Masks

    A Berlin court convicted three individuals, including a tax adviser, tied to a €50 million ($57.1 million) value-added tax fraud involving luxury vehicles and medical face masks, the European Public Prosecutor's Office said Tuesday.

  • July 14, 2026

    Greece Seizes Evidence In Suspected €46.9M VAT Fraud

    Greek authorities seized evidence and assets from companies tied to a suspected value-added tax fraud scheme involving small electronic goods that produced €46.9 million ($53.6 million) in lost tax revenue, the European Public Prosecutor's Office said Tuesday.

  • July 14, 2026

    EU Tax Lead Urges Reconsideration Of Interest Limit Rule

    Policymakers should reflect on the rationale behind the European Union's interest limitation rule — a tool that can increase firms' tax bases — as it is hitting companies that aren't circumventing tax mandates, a senior EU official said Tuesday.

  • July 13, 2026

    Israeli Law Firm Counters Gov't Bid To Toss GILTI Reg Suit

    An Israeli law firm asked the D.C. federal court Monday to disregard the government's attempt to end its suit aiming to scrap regulations that implemented the 2017 tax law's global intangible low-taxed income regime, arguing that its case is strong enough for a quick win.

  • July 13, 2026

    McKesson Says IRS Overreads Law Backing Pricing Rules

    Pharmaceutical giant McKesson asked a Texas federal court to invalidate transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. government mistakenly thinks the underlying statute gives the IRS "near-limitless authority" to define key terms.

  • July 13, 2026

    Biofuel Tax Fraudster Loses Bid For Extra Sentence Reduction

    A Utah federal judge declined to reduce further the original sentence of an accomplice in a $500 million biofuel production tax credit fraud scheme, finding that his prior reduction to 12 years had sufficiently reflected his cooperation in the trial of another defendant.

  • July 13, 2026

    US Biz Group Urges EU To Honor Side-By-Side Treatment

    A lobbying group representing U.S. companies called on the European Union to respect the country's side-by-side agreement as the bloc continues to work on a tax simplification overhaul.

  • July 13, 2026

    UK Gov't To Implement Side-By-Side Tax Rules

    Britain's tax authority set out new rules for the U.K.'s top-up tax regime, including the side-by-side safe harbor rule for U.S. multinational companies, according to a policy paper published Monday.

  • July 13, 2026

    Bin Maker Too Late To Appeal £161K Tax Bill, Tribunal Says

    A trash bin maker is time-barred from appealing more than £161,000 ($215,000) in customs duties and import value-added tax levied on its products, the First-tier Tribunal said in a decision.

  • July 13, 2026

    UK To Exempt Stablecoins From Capital Gains Tax

    Britain's tax authority will allow a capital gains tax exemption for disposals of stablecoins pegged to a fiat currency or other tangible assets, according to a policy paper published Monday.

  • July 13, 2026

    HMRC Sets Out Oil & Gas Levy To Replace Windfall Tax

    Britain's tax authority laid out the new tax regime for North Sea oil and gas to replace the windfall levy on energy giants in a policy paper published Monday.

  • July 10, 2026

    US-Canada Stalemate Expected To Hold Amid USMCA Review

    The trade stalemate between the U.S. and Canada is likely to continue through a drawn-out review process for the U.S.-Mexico-Canada Agreement, though companies will benefit from an underlying level of stability as the deal remains in effect, trade lawyers said.

Expert Analysis

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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
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    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

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    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

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    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

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    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.

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