International

  • 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.

  • August 27, 2026

    Canadian Charity Loses Bid For Dividend Tax Refund From US

    A Canadian charity cannot receive a tax refund from the Internal Revenue Service for U.S.-sourced dividend income from a unit trust because the U.S.-Canada tax treaty doesn't grant Canadian unit trusts that benefit, the United States Court of Federal Claims ruled.

  • August 27, 2026

    HMRC Says 240 People Had Crypto Gains Over £1M Last Year

    Two hundred and forty people reported capital gains from cryptocurrency that exceeded £1 million ($1.36 million) in the 2024-2025 tax year, collectively making about £717 million, HM Revenue & Customs said Thursday in its first dissemination of capital gains tax data specific to cryptocurrencies.

  • August 27, 2026

    Claims Court Halts BMW's $38M Tax Bid Over COVID Tolling

    The U.S. Court of Federal Claims paused reviewing luxury automaker BMW's $38.4 million tax refund suit until an appeals court issues a decision in a similar case over the tolling of a COVID-19-era filing deadline.

  • August 27, 2026

    States Push EU Budget Cuts As Spending, Tax Talks Ramp Up

    Six European Union countries called Thursday for the bloc's long-term budget draft to be cut by several hundred billion euros from the €2 trillion ($2.33 trillion) proposed by the European Commission.

  • August 27, 2026

    UN Cross-Border Tax Draft Risks Double Taxation, NFTC Says

    A proposed cross-border services tax framework from the United Nations could lead to double taxation due to its wide-ranging scope and broad sourcing rules, the National Foreign Trade Council said.

  • August 27, 2026

    Tax Pro Avoids Jail For Role In 'Singapore Solution' Fraud

    A New York federal judge on Thursday allowed an English national to avoid prison for facilitating a $60 million tax evasion scheme, after he admitted helping wealthy clients move money from a Swiss bank through his Hong Kong financial services business.

  • August 27, 2026

    Report Urges EU Tax Alignment Alongside Avoidance Rules

    The European Union should harmonize corporate tax across its member states as anti-avoidance rules have made investment more sensitive to national differences, a think tank said Thursday.

  • August 26, 2026

    OECD Says Peru Should Broaden Tax Base, Revise Breaks

    Peru should expand its tax base to more businesses and workers, revise tax expenditures like reduced rates, apply levies to capital income at slightly higher rates and cut tax allowances for labor income to improve its underperforming tax system, the OECD said in a report.

  • August 26, 2026

    Tax Breaks Cost Ireland €9.8B, Report Says

    The Irish government has forgone approximately €9.8 billion ($11.4 billion) in revenue in 2025 due to several tax breaks, including measures tied to personal and corporate income, the country's finance department said in a report Wednesday.

  • August 26, 2026

    Next Phase Of IEEPA Refund System 'Temporarily Delayed'

    U.S. Customs and Border Protection has "temporarily delayed" the rollout of the next portion of its system for refunds of the struck-down global tariff regime while it makes sure the system doesn't incorrectly affect other paid duties, it told the U.S. Court of International Trade.

Expert Analysis

  • 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.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • What To Note As UK Adopts OECD Crypto Disclosure Rules

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    With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

  • Attacks On Judicial Independence Tend To Manifest In 3 Ways

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    Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.

  • Section 899 Could Be A Costly Tax Shift For US Borrowers

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    Intended to deter foreign governments from applying unfair taxes to U.S. companies, the proposal adding new Section 899 to the Internal Revenue Code would more likely increase tax burdens on U.S. borrowers than non-U.S. lenders unless Congress limits its scope, says Michael Bolotin at Debevoise.

  • Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use

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    The recent revelation that a handful of questions from the controversial California bar exam administered in February were drafted using generative artificial intelligence demonstrates the continued importance of disclosure for attorneys who use AI tools, say attorneys at Troutman.

  • In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable

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    The U.S. District Court for the Eastern District of Virginia was again one of the fastest civil trial courts in the nation last year, and an interview with the court’s newest judge provides insights into why it continues to soar, says Robert Tata at Hunton.

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