International

  • November 25, 2025

    Profit Shifting Signs Persist Despite Waning, OECD Says

    Signs of profit shifting by multinational companies remain persistent despite some abatement over the past several years, the Organization for Economic Cooperation and Development said Tuesday.

  • November 25, 2025

    4 Things To Watch As UK Releases Budget

    The U.K.'s Labour government is set to release an autumn budget Wednesday that faces a test of balancing a pledge not to raise working people's taxes with an expected need to boost revenue to meet fiscal rules. Here are four things to watch for as the budget is issued.

  • November 25, 2025

    IRS To Propose Regs On Repeal Of CFC Tax Year Deferral

    The IRS intends to issue proposed regulations that address the repeal of a provision that allowed a controlled foreign corporation to begin its tax year one month earlier than its majority shareholder in the U.S., the agency said Tuesday.

  • November 25, 2025

    Half A Million Pensioners 'At Risk Of Paying Income Tax'

    An additional half a million state pensioners would pay income tax if the government extends the freeze on thresholds for another two years, a former pensions minister has said.

  • November 24, 2025

    HMRC Updates Guidance For Digital Tax Filings

    HM Revenue & Customs updated guidance Monday for its project to digitalize tax self-assessment, including new guidelines on the digital records regarding income and other information that taxpayers will need to submit.

  • November 24, 2025

    Malaysia's DST Must Avoid Bias Against US, Minister Says

    Malaysia will not impose a digital services tax that discriminates against American companies under its U.S. trade agreement, the country's Minister of Digital told lawmakers Monday, maintaining that this won't restrict the country's sovereignty.

  • November 24, 2025

    AICPA Urges Allowing Barred Foreign Losses For Use In US

    Losses that aren't allowed to reduce tax liabilities abroad should be accepted in the U.S. under rules surrounding dual consolidated losses because they don't cause the dual deductions that those rules aim to prevent, the American Institute of Certified Public Accountants said Monday.

  • November 24, 2025

    G20 Countries Working To Address Pillar 2 Concerns

    Group of 20 nations are negotiating with countries at the Organization for Economic Cooperation and Development to address concerns regarding the 15% global minimum tax agreement known as Pillar Two, G20 leaders announced during their Johannesburg summit.

  • November 21, 2025

    Judge Halts IRS-ICE Info-Sharing Agreement

    A D.C. federal judge temporarily stopped the IRS on Friday from sharing confidential taxpayer addresses with immigration enforcement officials, saying the agency's disclosures of addresses in August under an information-sharing deal were unlawful.

  • November 21, 2025

    IRS Finalizes Stock Buyback Tax Regs Without 'Funding Rule'

    The Internal Revenue Service released final regulations Friday for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule, which would apply the levy to a U.S. subsidiary of a foreign parent company.

  • November 21, 2025

    Trump Excludes Some Brazilian Foods From Higher Tariffs

    President Donald Trump has excluded many Brazilian food products from a 40% tariff, including coffee, cocoa, beef and fruits, after receiving word initial progress has been made in ongoing trade negotiations, according to an executive order.

  • November 21, 2025

    Key Issues Facing The IRS Amid Looming Budget Cuts

    The Internal Revenue Service is facing steep budget cuts in 2026, raising concerns about the agency's ability to handle taxpayer services and enforcement operations that are crucial for bringing in revenue and maintaining compliance with the voluntary system. Here, Law360 looks at the key areas where resource constraints are expected to hamper the IRS and what practitioners can do in response.

  • November 21, 2025

    UK Inheritance Tax Revenue Up 4% So Far In 2025

    The government collected £5.2 billion ($6.8 billion) in inheritance tax between April and October, figures published on Friday by Britain's tax authority show, extending a record-setting trend in the 2025/26 financial year.

  • November 20, 2025

    Importers Left With Uncertainty After US-China Trade Truce

    U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation.

  • November 20, 2025

    Treasury To Curtail Tax Credits For Unauthorized Immigrants

    The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday.

  • November 20, 2025

    EU Needs Unified Tax Benefits For Electricity, Experts Say

    The European Union needs a unified approach to tax benefits that would treat electricity more favorably than fossil fuels amid an impasse surrounding its overhaul to the energy taxation system, experts told the European Parliament's tax committee Thursday.

  • November 20, 2025

    FBAR Penalty Against Ex-Prof Is Constitutional, Court Says

    A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it.

  • November 20, 2025

    EU Council Approves Tax Deal Changes With 5 States

    The Council of the European Union said Thursday that it has approved updates to tax agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland, including new rules to help prevent tax evasion and fraud.

  • November 19, 2025

    Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real

    A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.

  • November 19, 2025

    Tax Court Upholds Rejection Of Tax Tipster's Award

    The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday.

  • November 19, 2025

    Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty

    Governments expressed widespread support for adopting measures to strengthen the mutual agreement procedure within a protocol on dispute resolution in the United Nations tax convention during the latest round of negotiations.

  • November 19, 2025

    Tax Court Substance Ruling Offers Silver Lining For Taxpayers

    Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions.

  • November 19, 2025

    OECD Releases Model Tax Treaty Updates For Amount B

    The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B.

  • November 19, 2025

    EU Tax Compliance Rules Raise €6.8B Annually, EC Finds

    The European Union's directive for administrative cooperation in taxation, known as DAC, has helped tax authorities generate €6.8 billion ($7.8 billion) a year in extra revenue, the European Commission said in a report Wednesday.

  • November 19, 2025

    Trump's Global Tariffs Curtailed Trade, Data Shows

    U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.

Expert Analysis

  • 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.

  • Playing Baseball Makes Me A Better Lawyer

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    Playing baseball in college, and now Wiffle ball in a local league, has taught me that teamwork, mental endurance and emotional intelligence are not only important to success in the sport, but also to success as a trial attorney, says Kevan Dorsey at Swift Currie.

  • 4 Former Justices Would Likely Frown On Litigation Funding

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    As courts increasingly confront cases involving hidden litigation finance contracts, the jurisprudence of four former U.S. Supreme Court justices establishes a constitutional framework that risks erosion by undisclosed financial interests, says Roland Eisenhuth at the American Property Casualty Insurance Association.

  • How Attys Can Use AI To Surface Narratives In E-Discovery

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    E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.

  • AbbVie Frees Taxpayers From M&A Capital Loss Limitations

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    The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.

  • ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'

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    The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.

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