International

  • 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.

  • August 28, 2026

    Trade Sanctions Body Refers More Than 40 Cases To HMRC

    The trade sanctions enforcer has revealed that it has referred almost 50 cases to law enforcement agencies and regulators for possible enforcement, including criminal prosecution, over the past year as its investigations begin to gather pace.

Expert Analysis

  • 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.

  • Can Companies Add Tariffs Back To Earnings Calculations?

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    With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.

  • A Look At DOJ's Dropped Case Against Early Crypto Operator

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    The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.

  • 8 Ways Lawyers Can Protect The Rule Of Law In Their Work

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    Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.

  • Law School's Missed Lessons: Communicating With Clients

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    Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

  • Navigating Antitrust Risks When Responding To Tariffs

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    Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.

  • Key Points From HMRC's Tax Reform Proposals

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    Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

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