International

  • June 22, 2026

    Irish Payments Show IP Returning To US, Tax Pro Says

    Ireland's payments to the U.S. for intellectual property showed a dramatic increase between 2020 and 2026, indicating that IP development returned to the U.S. after the implementation of the 2017 Tax Cuts and Jobs Act, the head of a Washington-based think tank said Monday.

  • June 22, 2026

    Developer Loses Appeal Over £33.5M Loan Tax Deduction

    A property development company isn't entitled to £33.5 million ($44.7 million) in tax relief claimed on payments made to a lender because there wasn't a strong enough causal link between the payments and its borrowing arrangements, a London tribunal ruled Monday.

  • June 22, 2026

    OECD Asks US To Fix Beneficial Ownership Transparency

    The U.S. is only partially compliant with its obligations to ensure the availability of beneficial ownership information, weighed down by its "deficient" definition of beneficial owners in tax filings, the OECD said in a report.

  • June 19, 2026

    UK Inheritance Tax Revenue Growth Slows

    Inheritance tax receipts for April and May reached £1.4 billion ($1.8 billion) in a slight dip in tax revenue compared with the 2025 tax take, despite frozen tax thresholds, according to official data published Friday.

  • June 18, 2026

    Securitization Cos. Can Duck EU Interest Limits, Adviser Says

    Luxembourg correctly exempted securitization companies from the interest limitation rule under the European Union's anti-tax avoidance directive because they are comparable to financial undertakings that are explicitly exempted, an adviser to the European Court of Justice said Thursday.

  • June 18, 2026

    Meta Says IRS Seeks 'Do-Over' Of Facebook Case

    The IRS, in increasing Meta's income under the periodic adjustment rule for years 2017-2019, is seeking a "do-over" of the Facebook case decided in 2025, valuing the same intangibles the U.S. Tax Court already valued under a different method, Meta argued.

  • June 18, 2026

    Medtronic Ruling Supports IRS In Amgen Case, Tax Court Told

    The IRS urged the U.S. Tax Court to back the agency's decision to allocate drugmaker Amgen's profits from the company's Puerto Rican subsidiary, arguing that the Eighth Circuit's ruling in Medtronic's case supports its pricing method.

  • June 18, 2026

    Indian Court Sides With US Gem Co. In Transfer Pricing Row

    A U.S. gem grading organization didn't have a taxable permanent establishment in India, and the government cannot tax royalties that the company refunded to its Indian counterpart, the Bombay High Court said in a judgment.

  • June 18, 2026

    Karaoke Chain Loses Bid For COVID VAT Refund

    A karaoke chain can't claim a value-added tax refund on bookings under a reduced rate for cultural shows and venues during the COVID-19 pandemic, a London tribunal has ruled, because the business's private rooms are exclusive.

  • June 18, 2026

    Tax Chief Expects Swift EU Agreement On Carbon Levy

    The Council of the European Union and the European Parliament are likely to agree on changes to carbon tax legislation within nine months, as their positions are largely aligned, the top civil servant in the European Commission's tax unit said Thursday.

  • June 17, 2026

    Tractor Supply Wrongly Shifted Income, SC Court Affirms

    South Carolina's tax agency did not exceed its authority when it imposed an alternative apportionment method on Tractor Supply Co. after asserting that the company and two affiliates had inappropriately shifted income to reduce state corporate tax liability, an appellate panel affirmed Wednesday.

  • June 17, 2026

    Tax Court Won't Rethink Basis Ruling Against Partnership

    A U.S. Tax Court judge said Wednesday that he won't reconsider his ruling that a company electing to be treated as a disregarded entity and attempting to pay for interest in a partnership with a promissory note from its parent can't claim a basis in the partnership.

  • June 17, 2026

    Varian Owes $7.2M After Deduction Limited, Tax Court Says

    Varian Medical Systems owes more than $7.2 million to the IRS as a result of the U.S. Tax Court limiting its deemed dividends deduction, the court said, accepting an agreement reached between the parties.

  • June 17, 2026

    Danish Financier Denied Tax Appeal For Missing Deadline

    A Danish financier and his company can't appeal a decision over a tax bill of over £866,000 ($1.2 million) despite his claim that they face a 200% tax rate, a London tribunal ruled, saying he had no good reason for missing a previous appeal deadline.

  • June 17, 2026

    Insurance Co.'s $1.35B Tax Fight Sent To Nova Scotia Court

    The Tax Court of Canada declined to hear Canadian revenue authorities' bid to include over CA$1.9 billion ($1.35 billion) worth of shares in a life insurance company's taxable capital, holding that jurisdiction belongs to a Nova Scotia court.

  • June 17, 2026

    VAT Break For Credit Management Has Limits, EU Court Says

    The European Union's value-added tax exemption for managing credit doesn't apply to management services provided by an entity that granted, transferred and continued managing the credit, an EU court said Wednesday in deciding questions for a Finnish bank's tax challenge.

  • June 17, 2026

    Hong Kong Tightens Bank Rules For Tax Info Exchanges

    Hong Kong lawmakers adopted a bill Wednesday to tighten requirements on financial institutions pursuant to the automatic exchange of information between tax authorities, building off suggestions made during a peer review of the jurisdiction's legal framework, the Inland Revenue Department said.

  • June 17, 2026

    HMRC Wins Top Court Case On Taxation Of Partnership Pay

    Britain's top court ruled on Wednesday that deferred pay distributed to individual partners at a foreign exchange trading firm must be taxed as income, giving a win to HM Revenue and Customs in its challenge to the company's remuneration structure.

  • June 16, 2026

    2nd Circ. Won't Let Man Reverse Tax Plea Over Bad Advice

    The Second Circuit issued a summary order Tuesday affirming the conviction of a Connecticut man who pled guilty to tax crimes, disagreeing that allegedly misleading advice from trial attorneys about the immigration implications of his plea warranted his withdrawing it.

  • June 16, 2026

    Israeli Law Firm Has No Case Against GILTI Regs, Gov't Says

    An Israeli law firm cannot challenge IRS regulations implementing the 2017 tax law's global intangible low-taxed income regime largely because any connected compliance burden is borne by its U.S. shareholder, not the firm itself, the government told a D.C. federal court.

  • June 16, 2026

    Arizonan Owes $1.9M For Unreported Accounts, 9th Circ. Says

    An Arizona man is on the hook for $1.9 million in penalties for undisclosed foreign bank accounts, the Ninth Circuit ruled, rejecting his contention that a district court mishandled the process for facilitating the IRS' recalculation of the amount.  

  • June 16, 2026

    KC Defends Gardener Trust Deal In £2M Evasion Trial

    A senior barrister accused of cheating the public purse out of almost £2 million ($2.7 million) argued Tuesday that his former gardener perfectly understood that an agreement to be compensated for his services via a trust was not binding.

  • June 16, 2026

    Revamp Of EU Tax Rules Set To Change Reporting Hallmarks

    A shake-up of European Union rules on tax information sharing is set to change criteria that trigger reporting obligations, notably tweaking hallmarks of potentially aggressive tax arrangements, according to draft revisions seen Tuesday by Law360.

  • June 16, 2026

    EU Parliament Approves Trade Deal With US

    European Union lawmakers voted Tuesday to approve legislation implementing the bloc's safeguard-bolstered trade deal with the U.S. founded on a series of tariff cuts, moving one step closer to implementation that is expected before the end of the month.

  • June 16, 2026

    UK Seeks Input On New Transfer Pricing Reporting Rules

    The British government is seeking feedback from businesses and other stakeholders on draft rules for new reporting requirements for international controlled transactions, HM Revenue & Customs said Tuesday.

Expert Analysis

  • How BigLaw Executive Orders May Affect Smaller Firms

    Author Photo

    Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.

  • Lawsuits Shouldn't Be Shadow Assets For Foreign Capital

    Author Photo

    Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.

  • How To Accelerate Your Post-Attorney Career Transition

    Author Photo

    Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.

  • Tariffs And FCA Create Perfect Storm For Importers

    Author Photo

    The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.

  • US Reassessment Of OECD Tax Deal Is Right Move

    Author Photo

    The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.

  • Measuring And Mitigating Harm From Discriminatory Taxes

    Author Photo

    In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.

  • Adapting To Private Practice: From DOJ Leadership To BigLaw

    Author Photo

    The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.

  • How The CRE Industry Is Adapting To Tariff Uncertainty

    Author Photo

    Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.

  • Law Firm Executive Orders Create A Legal Ethics Minefield

    Author Photo

    Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.

  • Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike

    Author Photo

    The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.

  • Firms Must Embrace Alternative Billing Models Or Fall Behind

    Author Photo

    As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.

  • How Attorneys Can Master The Art Of On-Camera Presence

    Author Photo

    As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.

  • Firms Still Have Lateral Market Advantage, But Risks Persist

    Author Photo

    Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

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