International

  • September 01, 2026

    Siemens Leaders Testify They Were Unaware Of Tax Strategy

    Three executives who described how Siemens' digital software business integrated Mentor Graphics' operations after acquiring that electronic design automation company in 2017 seemed oblivious to the tax aspects of the restructuring that occurred in 2018, their testimony Monday and Tuesday showed.

  • September 01, 2026

    Investment Co. Disputes IRS' $166M Add-On To Capital Gains

    An investment company accused the IRS of mistakenly inflating its 2008 short-term capital gains from certain securities investments to about $170 million from $4 million, telling the U.S. Tax Court the gains were properly deferred during the Great Recession.

  • September 01, 2026

    Valid Regs Require Abbott To Pay Tax On $8B Gain, IRS Says

    The IRS urged the U.S. Tax Court to validate regulations that the agency said required Abbott Laboratories to pay taxes on an $8 billion gain stemming from transactions between its foreign affiliates, arguing the pharmaceutical giant is pushing for "an inappropriately rigid" statutory interpretation.

  • September 01, 2026

    China Ends Tax Break For Foreign Investor Dividends

    Individual foreign investors who receive dividends and bonuses from Chinese companies with foreign capital investments are now liable for a 20% withholding tax on that income, the government said Tuesday, ending a tax break in place since 1994.

  • September 01, 2026

    UK Maps Out Pension Fund Inheritance Tax Reporting Rules

    The U.K. government set out further detail on inheritance tax reporting rules to be rolled out for pension schemes as part of fiscal changes to bring unused pension pots into taxation in April 2027, according to a policy paper.

  • September 01, 2026

    Sweden To Let Unlisted Cos. E-File Withholding Tax Info

    Unlisted Swedish companies that manage their own share registries would be able to file withholding tax information electronically to the Swedish Tax Agency under a bill proposed Tuesday by the Ministry of Finance.

  • September 01, 2026

    Temporary Tariffs Exceeded Trump's Power, Fed. Circ. Told

    President Donald Trump illegally based his temporary tariffs on the misapplication of a law allowing the president to address balance-of-payment deficits, two businesses told the Federal Circuit, pushing the court to preserve a U.S. Court of International Trade ruling against the tariffs.

  • September 01, 2026

    Ireland Proposes Retail Investment Accounts With Flat Tax

    Ireland wants to create accounts for Irish retail investors with a flat-rate tax on the account value above an exempted threshold, which would simplify the investment tax system compared to current rules, the government said.

  • September 01, 2026

    Frozen Tax Bands Drag 1M Pensioners Into Higher Rates

    The U.K. has seen more than 1 million pensioners dragged into higher income tax bands as a result of tax thresholds being frozen for five years, according to HM Revenue & Customs data revealed Tuesday.

  • September 01, 2026

    UN Tax Pact Should Avoid Gross Basis Taxes, Businesses Say

    The United Nations' tax convention should avoid gross basis withholding taxes, which could weaken trade and competitiveness while raising costs throughout supply chains, the International Chamber of Commerce said in comments for a consultation.

  • September 01, 2026

    Start Of EU Tax Simplification Talks Will Cover Anti-Avoidance

    Early discussions among European Union countries on tax simplification will begin Thursday with a focus on the anti-tax avoidance directive, according to a steering note seen Tuesday by Law360.

  • August 31, 2026

    Siemens Urges Court Toward Wide View Of 2018 Restructuring

    An attorney for Siemens USA asked the U.S. Tax Court on Monday to consider all elements of the restructuring that followed the company's 2017 acquisition of Mentor Graphics and led to a $3.5 billion deduction the following year.

  • August 31, 2026

    States Ask Fed. Circ. To Revive Their Temporary Tariff Claims

    Two dozen states pushed the Federal Circuit on Monday to revive their specific claims against now-expired temporary tariffs while simultaneously pushing the panel to otherwise back the U.S. Court of International Trade's ruling that the tariffs were illegal.

  • August 31, 2026

    Investors Can't Escape Danish Tax Fraud Case, 2nd Circ. Says

    Four investors and their pension plans owe $476 million for their role in a tax fraud scheme against the Danish government, the Second Circuit affirmed Monday, rejecting the investors' contention that they are beyond the reach of Danish revenue collectors.

  • August 31, 2026

    Levi Strauss Buyer Seeks Refund After Trump Tariffs Tossed

    Levi Strauss & Co. has yet to provide a way for its customers to get refunds of unlawful tariff-related costs they had to pay for imported goods affected by President Donald Trump's since-invalidated global "tariff regime," alleges a proposed class action filed in Louisiana federal court Friday. 

  • August 31, 2026

    Canada, France Treaties Don't Ax Investment Tax, Court Says

    U.S. tax treaties with Canada and France don't shield taxpayers from the net investment income tax because the treaties' foreign tax credits are subject to limitations in the Internal Revenue Code, the Court of Appeals for the Federal Circuit said Monday, reversing two decisions.

  • August 31, 2026

    Tax Court Says Trader Didn't Aid In $7.3B IRS Probe

    A U.S. Tax Court judge rejected a former stock trader's claim for a whistleblower award Monday, saying he did not play a significant role in Internal Revenue Service investigations into digital option tax shelters that recovered at least $7.3 billion.

  • August 31, 2026

    Trump Opening 1st Round Of Tariff-Free Ground Beef Tuesday

    The first 100,000 of a total 300,000 metric tons of ground beef that can be imported into the U.S. without an added tariff can enter into the country starting Sept. 1, according to a proclamation published Monday.

  • August 31, 2026

    Canada Court Backs Ex-Blue Jays' Income Tax Formula

    Two former Major League Baseball stars who played for the Toronto Blue Jays need to subtract their tax-free retirement contributions from only their Canadian income and not their U.S. earnings as well, a Canadian appeals court affirmed.

  • August 31, 2026

    Hong Kong's Tax Filing System Caused Trouble, Report Says

    A significant number of Hong Kong taxpayers didn't finish filing taxes through the territory's online portal last year primarily because of unclear instructions, the Office of the Ombudsman said Monday.

  • August 28, 2026

    Canada Appeals Court Nixes Tax Liability Over $65M Mall Sale

    A Canadian real estate company is off the hook for additional taxes stemming from a CA$89.8 million ($64.6 million) property sale, a Canadian appeals court ruled, rejecting a lower court's finding that the transaction was not negotiated at arm's length.

  • August 28, 2026

    G20 Trade Rises In Second Quarter Of 2026, OECD Says

    International trade in goods and services rose substantially among the Group of 20 nations in the second quarter of this year, driven by goods imports in places like the U.S. and services exports in places like China, the OECD said Friday.

  • August 28, 2026

    EU Draft Tax Data Bill Eases US Access To Carveout

    A draft of a European Union bill on tax data exchange seen Friday by Law360 emphasized that companies should not be barred from accessing a reporting carveout because they are headquartered in a Pillar Two side-by-side regime — a suggestion that could benefit U.S. companies.

  • August 28, 2026

    IRS Corrects Proposed Regs On Foreign Tax Rules

    The Internal Revenue Service issued a notice Friday to correct several aspects of proposed regulations issued this month that relate to allocating foreign taxes following the repeal of a deferral election and the disallowance of foreign tax credits on certain distributions of previously taxed earnings.

  • August 28, 2026

    Siemens To Defend Restructuring, $3.5B Deduction At Trial

    A U.S. subsidiary of German conglomerate Siemens is preparing to defend a $3.5 billion deduction stemming from transactions that the company said were needed to integrate a 2017 acquisition into its software business unit when its U.S. Tax Court trial begins Monday.

Expert Analysis

  • BigLaw Settlements Should Not Spur Ethics Deregulation

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    A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.

  • 5 Ways Lawyers Can Earn Back The Public's Trust

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    Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.

  • Legal Jeopardy Looms Over Trump's Trade Negotiation Plans

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    Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.

  • What US-India Trade Deal Will Mean For Indian Pharma

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    Complicated by newly imposed tariffs from the U.S., the outcome of the U.S.-India trade talks is poised to reshape not just trade policy, but also the strategic alignment of the two countries' pharmaceutical ecosystems, says Jashaswi Ghosh at Holon Law Partners.

  • Bar Exam Reform Must Expand Beyond A Single Updated Test

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    Recently released information about the National Conference of Bar Examiners’ new NextGen Uniform Bar Exam highlights why a single test is not ideal for measuring newly licensed lawyers’ competency, demonstrating the need for collaborative development, implementation and reform processes, says Gregory Bordelon at Suffolk University.

  • A Simple Way Courts Can Help Attys Avoid AI Hallucinations

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    As attorneys increasingly rely on generative artificial intelligence for legal research, courts should consider expanding online quality control programs to flag potential hallucinations — permitting counsel to correct mistakes and sparing judges the burden of imposing sanctions, say attorneys at Lankler Siffert & Wohl and Connors.

  • The Legal Education Status Quo Is No Longer Tenable

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    As underscored by the fallout from California’s February bar exam, legal education and licensure are tethered to outdated systems, and the industry must implement several key reforms to remain relevant and responsive to 21st century legal needs, says Matthew Nehmer at The Colleges of Law.

  • 6 Questions We Should Ask About The Trump Trade Deals

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    Whenever the text becomes available, certain questions will help determine whether the Trump administration’s trade deals with U.S. trading partners have been crafted to form durable economic relationships, or ephemeral ties likely to break upon interpretive disagreement or a change in political will, says Ted Posner at Baker Botts.

  • E-Discovery Quarterly: Rulings On Relevance Redactions

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    In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.

  • Section 1983 Has Promise After End Of Nationwide Injunctions

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    After the U.S. Supreme Court recently struck down the practice of nationwide injunctions in Trump v. Casa, Section 1983 civil rights suits can provide a better pathway to hold the government accountable — but this will require reforms to qualified immunity, says Marc Levin at the Council on Criminal Justice.

  • Playing Soccer Makes Me A Better Lawyer

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    Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.

  • Adapting To Private Practice: From ATF Director To BigLaw

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    As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.

  • How Cos. In China Can Tailor Compliance Amid FCPA Shifts

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    The U.S. Department of Justice’s recently updated Foreign Corrupt Practices Act enforcement guidelines create a fluid business environment for companies operating in China that will require a customized compliance approach to navigate both countries’ corporate and legal systems, say attorneys at Dickinson Wright.

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