International
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October 06, 2026
EU Lawmakers Seek Fixes For US Global Minimum Tax Deal
The European Parliament on Tuesday asked the bloc's executive branch to propose ways "to correct the structural imbalances" created by a deal with the United States to exempt American companies from the international provisions of the 15% global minimum tax.
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October 06, 2026
Hungary's Government Proposes 1% Wealth Tax
Hungary wants to levy an annual 1% wealth tax on fortunes above 1 billion Hungarian forints ($3.07 million) starting at the end of this year, roping in assets held abroad and those held by trusts, private foundations and nonresidents, the government said Tuesday.
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October 06, 2026
Ireland Plans To Lift Threshold For Higher Tax Rate In Budget
The Irish government said Tuesday that it will increase a threshold at which a higher rate of income tax is due as part of its 2027 budget package.
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October 05, 2026
Novel Strategy Prompted ETF Guidance, Treasury Atty Says
The U.S. Department of the Treasury's recent revenue ruling and notice cracking down on improper arrangements using legitimate exchange-traded fund conversions was a response to a marketed transaction that was not squarely addressed by existing rules targeting abusive practices, a department official said Monday.
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October 05, 2026
Tax Pros From Brazil, Canada Highlight APA Challenges
Brazil's nascent transfer pricing system isn't yet prepared for an influx of advance pricing agreement requests, a tax specialist from that country said Monday, while a Canadian attorney said the APA process in his country increasingly resembles an in-depth audit.
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October 05, 2026
Philippine Airlines Asks Tax Court To Cut $5.7M Off Tax Bill
The IRS cannot deny Philippine Airlines a tax exemption on income from passengers and excess baggage just because the Philippines taxes cargo income, the airline told the U.S. Tax Court in a bid to cut more than $5.7 million off a $7.1 million tax bill.
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October 05, 2026
Bilzin Sumberg Expands Tax Practice With Nelson Mullins Atty
Bilzin Sumberg Baena Price & Axelrod LLP has expanded its tax and private wealth practice with the addition of a Miami-based partner from Nelson Mullins Riley & Scarborough LLP.
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October 05, 2026
White & Case Hits Back At Agency Over Flawed-Advice Claim
White & Case LLP has denied responsibility for £2.6 million ($3.4 million) in alleged tax liabilities, arguing that a lettings agency sought advice from Laytons LLP before deciding to pay millions in dividends to offshore trusts.
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October 05, 2026
IRS Leaked Whistleblower's Tax Info to DOJ, Agent's Suit Says
An agent in the IRS Criminal Investigation unit has accused the agency of leaking his personal tax information to the U.S. Department of Justice in retaliation against him for blowing the whistle on what he said was mismanagement in the branch's Chicago office.
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October 05, 2026
High Court Won't Consider $30M Argentine Bondholder Claim
Argentine bondholders claiming the Second Circuit wrongly upheld a block of over $30 million in contractual claims against Argentina won't get a chance to argue their stance at the U.S. Supreme Court, as the justices declined on Monday to review the case.
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October 05, 2026
Justices Won't Hear Corporate Transparency Act Challenges
The U.S. Supreme Court on Monday declined to hear two cases challenging the Corporate Transparency Act, a law designed to establish a national beneficial ownership registry for law enforcement agencies investigating shell companies that was severely curtailed by the U.S. Department of the Treasury.
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October 05, 2026
EU Proposes Extension Of VAT Fraud-Fighting Tool
The European Union suggested extending a mechanism that permits a shift in value-added tax liability from seller to business customer in an attempt to tackle fraud until new digital reporting rules start in July 2030.
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October 05, 2026
1M More Taxpayers To Face New Digital Filing Rules, UK Says
The U.K.'s tax authority urged sole traders and landlords Monday to get ready to comply with digital recordkeeping requirements by April, when more than 1 million more people will become subject to the rules under an effort to modernize tax processes.
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October 02, 2026
Int'l Tax In September: Facebook Ruling, BEAT Bill And More
September kicked off with the announcement of tariffs on semiconductors and ended with the U.S. Tax Court's long-awaited ruling on a computational dispute involving Facebook, with Siemens USA's trial and a bill that would change the U.S. base erosion and anti-abuse tax in the middle. Here, Law360 looks at some of the biggest international tax developments of the past month.
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October 02, 2026
DOJ Can't Reverse IRS Curtailing Of $2.4M Penalty, Court Says
The Department of Justice lacked the authority to reverse the IRS' abatement of a man's penalty of nearly $2.4 million for promoting abusive tax shelters after the agency realized a supervisor hadn't signed off on it, an Illinois federal court said.
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October 02, 2026
Dems Slam Proposed Limit On Tax Credits For Immigrants
A group of Democratic senators urged the U.S. Department of the Treasury to scrap proposed rules that would cut off refundable tax credits to certain immigrants living in the U.S. legally, arguing that the guidance oversteps regulatory authority and would create a "byzantine" system.
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October 02, 2026
Former Fla. Rep. Gets 10 Years In Venezuela FARA Case
A Florida federal judge on Friday sentenced ex-Florida Rep. David Rivera to 10 years in prison for failing to register as a foreign agent and laundering the proceeds of a $50 million contract with a unit of Venezuela's state-owned oil company.
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October 02, 2026
Taxation With Representation: Hogan Lovells, Davies, Sidley
In this week's Taxation With Representation, semiconductor company Advanced Micro Devices buys AI model developer and research lab World Labs, Brixmor Property Group and private investment management firm Everview Partners acquire Slate Grocery REIT, and cyberintelligence company REDLattice merges with blank check company Bold Eagle Acquisition Corp.
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October 02, 2026
Tax Burden Costing Hospitality Jobs, Investment, Groups Say
Hospitality and retail face the highest effective tax rate of any sector in the U.K., resulting in lower investment, fewer jobs and higher prices for customers, according to a report by a retail industry group.
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October 01, 2026
MPs Ask HMRC To Review Tax Implications Of Man City Case
An influential cross-party group of MPs Monday called on HM Revenue & Customs to consider any tax implications from the bombshell findings that Manchester City used "sham" contracts to boost its income by around £900 million ($1.2 billion).
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October 01, 2026
Finland Proposes Tax Changes For Corporate Restructures
Finland's government has put forward amendments aimed at expanding options for tax-neutral corporate restructuring and allowing related deductions, the Ministry of Finance said Thursday.
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October 01, 2026
EU Warns 5 Countries Over Low Fines Tied To Tax Info Swaps
The European Commission warned Germany, Estonia, Latvia, Lithuania and Hungary that their penalties are "manifestly too low" to deter noncompliance with companies' obligations to file information for exchanges between tax authorities, including country-by-country tax reports and top-up tax returns for the global minimum tax.
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October 01, 2026
Greece Urges Looser EU Spending Limit Amid Energy VAT Lift
Greece called on the European Union to loosen its spending rules for member states, particularly given a boost in value-added tax revenue, to help countries that wish to enact energy affordability support, according to a letter seen by Law360 on Thursday.
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October 01, 2026
Brazil Adopts Updated Pillar Two Substance-Based Tax Breaks
The Brazilian government announced plans Thursday to incorporate the OECD's updates to a 15% global minimum tax agreement known as Pillar Two to give multinational corporations additional tax benefits that are tied to economic substance in the country.
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October 01, 2026
EU Nations Push For OECD Alignment On Platform Tax Rules
Several European Union countries said during a working group meeting that the bloc's revisions to tax data-sharing legislation for digital platforms must remain aligned with rules developed at the Organization for Economic Cooperation and Development, three EU officials told Law360 on Thursday.
Expert Analysis
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5 Things Associates Must Ask About Their Firm's Merger Plan
The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.
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2 'Rocket Dockets' And The Rules That Propel Them
The fastest civil trial courts in the country are currently in the Eastern District of Virginia and the Southern District of Florida, and their chief judges provide insights into the court rules that keep them ahead, says Robert Tata at Hunton.
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Your Next Litigation Hold Should Cover AI Chat Logs
The Delaware Chancery Court’s recent decision in Fortis Advisors v. Krafton to treat a CEO’s artificial intelligence chats as substantive evidence is being read as a discovery warning to litigators, but there is a second duty-to-preserve lesson that is especially pertinent to in-house counsel, say attorneys at Faegre Drinker.
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Studying Foreign Languages Makes Me A Better Lawyer
Studying Italian and Japanese has shown me that learning a new language can benefit a legal career in several ways, including by demonstrating the importance of approaching problems from a fresh perspective and the value of practicing patience with colleagues and clients, says Anna King at Genworth Financial.
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Sold Inventory May Drive Tax Treatment Of Tariff Refunds
Companies determining the tax treatment of refunds expected following the U.S. Supreme Court's February decision invalidating tariffs imposed under the International Emergency Economic Powers Act should consider whether the tariff costs have already reduced their income considering the cost of goods sold, say attorneys at McDermott.
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Adapting To AI-Driven Scrutiny Of Foreign Asset Disclosures
As the government expands AI-driven, cross-agency fraud detection, foreign asset disclosure should be viewed as part of a broader, data‑driven enforcement ecosystem that prioritizes consistency, documentation and proactive governance, says Logan Koehring at FBT Gibbons.
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Tax Teams Get No Bright-Line Rule From AI Privilege Cases
Three recent appellate decisions that considered artificial intelligence in the context of attorney-client privilege protections illustrate that taxpayers and tax practitioners alike must consider the pertinent facts on a case-by-case basis, with particular attention to confidentiality, disclosure risk and system design, say attorneys at Morgan Lewis.
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NY Times Word Puzzles Make Me A Better Lawyer
Every morning I let The New York Times humble me with word games, which offer a chance to recalibrate my brain before the day's chaos arrives and remind me that a solution — whether to a puzzle or employment law issue — almost always exists once I find the right angle, says Amy Epstein Gluck at Pierson Ferdinand.
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Law School's Missed Lesson: Diagnose Before Arguing
Law school often skips over explicitly teaching students how to determine what kind of problem a case presents before they commit to a particular doctrinal path, which risks building arguments that are internally coherent but externally misaligned, says Melanie Oxhorn at Kobre & Kim.
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Judges On AI: How Courts Can Survive The Tech Revolution
Colorado Supreme Court Justice Maria Berkenkotter and Colorado Court of Appeals Judge Lino Lipinsky de Orlov discuss how artificial intelligence has already fundamentally altered the legal system and offer tips for courts navigating deepfakes, hallucinations and a gap in access to AI tools.
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3 AI Adoption Mistakes GCs Should Avoid
The pressure in-house legal teams face to quickly adopt artificial intelligence tools, combined with budget constraints and the need to evaluate a crowded market of options, sets the stage for implementation mistakes that are often difficult to undo, says former 23andMe general counsel Guy Chayoun.
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4 Emerging Approaches To AI Protective Order Language
Over the last year, at least five federal district courts have issued or analyzed specific protective order provisions restricting the use of generative artificial intelligence platforms with protected materials, establishing that proactive AI-specific provisions are now standard practice and demonstrating that no single model works for every case, says Joel Bush at Kilpatrick.
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Heppner Ruling Left AI Privilege Risk For Lawyers Unresolved
While a New York federal judge’s recent ruling in U.S. v. Heppner resolved a privilege question surrounding client-side artificial intelligence use, it did not address how to mitigate the risks that can arise when confidential information enters the operative context of an AI system used by an attorney, says Jianfei Chen at Quarles & Brady.