International
-
January 13, 2026
Pair Say IRS Records Undercut US In $1.8M Tax Dispute
Internal Revenue Service documents show that a formerly married couple's refund claim was properly received, undermining the government's position that they improperly filed a refund claim for tax penalties of over $1.8 million relating to a foreign trust, they told a Pennsylvania federal court.
-
January 12, 2026
Trump Says 25% Tariff Incoming For Iranian Biz Dealings
Any country with economic ties to Iran could face a 25% tariff immediately on their goods exported to the U.S., President Donald Trump said Monday on social media.
-
January 12, 2026
Solar Co. Blames Broker's Error For $6M Tariff Bill
A renewable energy company wants its customs broker and agent held responsible for over $6 million in antidumping and countervailing duties it had to pay on imported solar panels due to the broker's alleged failure to properly record them.
-
January 12, 2026
India High Court Rules Post-Merger Shares Can Be Taxed
The Supreme Court of India ruled that if companies combine to create a new business with shares that are worth more than those of the individual corporations, investors may owe taxes on the difference in value.
-
January 12, 2026
OECD Issues Guidance On Real-Time Reporting For VAT
The OECD has released guidance for policymakers on designing mandates for real-time reporting of transactions to tax authorities for value-added tax purposes, which are increasingly being considered and adopted by countries worldwide.
-
January 09, 2026
EU Council Approves Trade Pact With 4 S. American Countries
A legislative arm of the European Union approved the bloc's free trade agreement with four South American countries Friday, taking steps to create the largest global free trade zone.
-
January 09, 2026
Taxation With Representation: King & Spalding, Torys, Milbank
In this week's Taxation With Representation, power generation company Vistra Corp. acquires Cogentrix Energy from Quantum Capital Group, real estate firm Minto Group partners with Crestpoint Real Estate Investments to take Minto's apartment-focused real estate investment trust private, and engineering services provider Jacobs acquires a remaining stake in PA Consulting.
-
January 09, 2026
China To Cut VAT Export Tax Rebates For Solar Panels
China will eliminate its value-added tax export rebates for photovoltaic and other related products starting April 1, the country's Ministry of Finance said Friday.
-
January 09, 2026
UK Gov't Rules Out Farm Inheritance Tax Concessions
The U.K.'s Labour government will not make more concessions to farmers on its inheritance tax rule changes for agricultural land after a recent compromise on the tax threshold, a minister said in a speech at a conference.
-
January 08, 2026
OECD, Gov't Officials Praise 'Side-By-Side' Tax Deal
Officials from Germany, the U.S. and the OECD on Thursday hailed a recently finalized agreement among roughly 150 countries as a balanced solution to the U.S.' desire for a global minimum tax regime that operates "side by side" with its own rules.
-
January 08, 2026
Courts Back Agencies Despite Loper Bright Ruling, DOJ Says
Appellate courts have mostly upheld federal agencies' interpretation of ambiguous statutes, including tax disputes, even after the U.S. Supreme Court's 2024 landmark decision that limited agency deference, a U.S. Department of Justice attorney said Thursday.
-
January 08, 2026
US Asks 6th Circ. To Revive Reg In $89M FedEx Tax Suit
The Sixth Circuit should vacate a judgment that allowed FedEx an $89 million refund by discarding a regulation preventing companies from claiming foreign tax credits on earnings offset by losses, which aren't taxed in the U.S., the government said in an opening brief.
-
January 08, 2026
Irish R&D Tax Credit Linked To €7B In Spending, Gov't Says
Ireland's tax credit for research and development is linked to €7 billion ($8.2 billion) in related spending by companies on the island in 2023 while costing the government about €1.4 billion, the Irish Department of Finance said Thursday.
-
January 08, 2026
Data Supervisor Warns Against Exceptional VAT Info Searches
The European Union's plans to crack down on value-added tax fraud may blur the line between data cooperation and law enforcement, potentially undermining data protection, the EU's data supervisor warned Thursday.
-
January 08, 2026
Audits Get Final Word On Economic Substance, IRS Atty Says
IRS attorneys provide legal guidance during audits on whether a transaction lacks economic substance, but examiners make the ultimate determination, an agency associate chief counsel said Thursday while explaining how the agency applies a powerful anti-abuse tool in audits.
-
January 08, 2026
HSBC To Pay €300M To Settle French Tax Fraud Probe
HSBC has agreed to pay French authorities more than €300 million ($350 million) in fines and unpaid taxes to settle a criminal probe into how the bank's Paris branch handled dividend arbitrage transactions between 2014 and 2019, public prosecutors revealed Thursday.
-
January 08, 2026
OECD Project Seeks To Ease Access To Tax Dispute Process
A new project at the OECD will aim to ensure that double-tax cases are eligible to be resolved through bilateral government negotiations under treaties no matter how they're characterized by a country's tax authority, a U.S. Treasury Department official said Thursday.
-
January 07, 2026
US Official Gives Rationale For OECD Global Mobility Changes
Recent changes to the commentary on when a home office gives rise to a permanent establishment in the OECD model tax treaty reflect delegates' unhappiness with previous language on the availability of an office, a U.S. Treasury Department official said Wednesday.
-
January 07, 2026
Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says
The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed Swiss account, the Second Circuit said Wednesday, upholding a lower court's judgment.
-
January 07, 2026
Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies
The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025.
-
January 07, 2026
Gov't Slow-Rolling Lower Fee For Expatriation, Court Told
The U.S. State Department has impermissibly slow-walked the rollout of a reduced fee for renouncing U.S. citizenship, a Paris-based group that represents Americans permanently residing abroad told a D.C. federal court.
-
January 07, 2026
Australia Increasingly Blocking Tax Debtors From Leaving
The Australian Taxation Office is increasingly barring international travel for people with tax debts who it suspects of trying to flee their obligations, it said Wednesday.
-
January 07, 2026
IRS Mulling Budget Bill's Changes To CFC Rules, Official Says
The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.
-
January 07, 2026
Irish Tax Revenue Up €8.6B In 2025, Corp. Taxes Up 17%
The Irish government saw tax revenue rise by €8.6 billion ($10 billion) in 2025, with corporate tax receipts up by 17.2%, the Department of Finance said in its annual report.
-
January 07, 2026
Portuguese Tax System Too Complex, OECD Says
The Portuguese government needs to simplify the country's tax regime to boost economic growth and raise living standards, the Organization for Economic Cooperation and Development said Wednesday.
IRS Asks 3rd Circ. To Uphold $100M Bill Against Hedge Fund
The Internal Revenue Service urged the Third Circuit to uphold a $100 million tax bill against a Cayman Islands hedge fund, arguing that the fund's U.S.-based investment manager carried out a domestic business beyond merely securing capital.
European Union Carrying Out Revised Min. Corp. Tax Regime
The European Union's executive body is implementing changes to the 15% minimum corporate tax regime across the trade bloc after a renegotiation of Pillar Two last week, according to a notice published Monday.
US Disputes Right To Trial Before IRS Assesses FBAR Fines
A California man wasn't entitled to a jury trial prior to the IRS assessing penalties for his failure to report foreign bank accounts because the U.S. Supreme Court decision he cited limiting administrative courts for securities fraud doesn't apply, the government told a California federal court.
IRS Asks 3rd Circ. To Uphold $100M Bill Against Hedge Fund
The Internal Revenue Service urged the Third Circuit to uphold a $100 million tax bill against a Cayman Islands hedge fund, arguing that the fund's U.S.-based investment manager carried out a domestic business beyond merely securing capital.
European Union Carrying Out Revised Min. Corp. Tax Regime
The European Union's executive body is implementing changes to the 15% minimum corporate tax regime across the trade bloc after a renegotiation of Pillar Two last week, according to a notice published Monday.
US Disputes Right To Trial Before IRS Assesses FBAR Fines
A California man wasn't entitled to a jury trial prior to the IRS assessing penalties for his failure to report foreign bank accounts because the U.S. Supreme Court decision he cited limiting administrative courts for securities fraud doesn't apply, the government told a California federal court.
Featured Stories
-
Federal Tax Policy To Watch In 2026
Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.
-
Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
-
Top International Tax Cases To Watch In 2026
Major multinational corporations such as McKesson and Coca-Cola will continue to litigate high-stakes international tax cases in 2026, including transfer pricing disputes with billions of dollars on the line and fights over whether regulations exceed the government's authority. Here, Law360 looks at four key international tax cases to follow in the new year.
Expert Analysis
-
OFAC Sanctions Will Intensify Amid Global Tensions In 2026
The Office of Foreign Assets Control will ramp up its targeting of companies in the private equity, venture capital, real estate and legal markets in 2026, in keeping with the aggressive foreign policy approach embraced by the Trump administration in 2025, say attorneys at Holland & Knight.
-
5 E-Discovery Predictions For 2026 And Beyond
2026 will likely be shaped by issues ranging from artificial intelligence regulatory turbulence to potential evidence rule changes, and e-discovery professionals will need to understand how to effectively guide the responsible and defensible adoption of emerging tools, while also ensuring effective safeguards, say attorneys at Littler.
-
2026 Enforcement Trends To Expect In Maritime And Int'l Trade
The maritime and international trade community should expect U.S. federal enforcement to ramp up in 2026, particularly via Office of Foreign Asset Control shipping sanctions, accelerating interagency investigations of trade fraud, and U.S. Coast Guard narcotics and pollution inspections, say attorneys at Holland & Knight.
-
Judges On AI: How Courts Can Boost Access To Justice
Arizona Court of Appeals Judge Samuel A. Thumma writes that generative artificial intelligence tools offer a profound opportunity to enhance access to justice and engender public confidence in courts’ use of technology, and judges can seize this opportunity in five key ways.
-
The Case For Emulating, Not Dividing, The Ninth Circuit
Champions for improved judicial administration should reject the unfounded criticisms driving recent Senate proposals to divide the Ninth Circuit and instead seek to replicate the court's unique strengths and successes, says Ninth Circuit Judge J. Clifford Wallace.
-
5 Tariff And Trade Developments To Watch In 2026
A new trade landscape emerged in 2025, the contours of which will be further defined by developments that will merit close attention this year, including a key ruling from the U.S. Supreme Court and a review of the U.S.-Mexico-Canada Agreement, says Ted Posner at Baker Botts.
-
4 Developments That Defined The 2025 Ethics Landscape
The legal profession spent 2025 at the edge of its ethical comfort zone as courts, firms and regulators confronted how fast-moving technologies and new business models collide with long-standing professional duties, signaling that the profession is entering a period of sustained disruption that will continue into 2026, says Hilary Gerzhoy at HWG Law.
-
How Fractional GCs Can Manage Risks Of Engagement
As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.
-
How OECD Tax Update Tackles Mobile Workforce Complexity
The Organization for Economic Cooperation and Development’s recently updated model tax convention — a recalibration of international tax principles in response to an increasingly mobile workforce — should prompt companies to reevaluate cross-border operations, transfer pricing policies and tax controversy strategies, say attorneys at Eversheds.
-
A Uniform Federal Rule Would Curb Gen AI Missteps In Court
To address the patchwork of courts’ standing orders on generative artificial intelligence, curbing abuses and relieving the burden on judges, the federal judiciary should consider amending its civil procedure rules to require litigants to certify they’ve reviewed legal filings for accuracy, say attorneys at Shook Hardy.
-
Supreme Court Term Limits Would Carry Hidden Risk
While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
-
Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave
The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.
-
AI Evidence Rule Tweaks Encourage Judicial Guardrails
Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.