International
-
September 08, 2026
Eaton Challenges IRS Example On Intercompany Loans
The IRS is misusing a regulatory example that is unrelated to its argument that Eaton cannot pay foreign affiliates for support that a lender would assume exists in the agency's bid to reduce related-party interest rates and fees, the company told the U.S. Tax Court.
-
September 08, 2026
OECD Says Corporate Tax Rates Stayed Flat At 21.2% In 2025
The average combined corporate income tax rate was 21.2% last year across many major economies, remaining basically flat for a third consecutive year, the OECD said Tuesday in a report, while a trend of sector-specific corporate tax hikes continued.
-
September 08, 2026
Aussie Tax Office Issues Royalty Guidance After Pepsi Ruling
The Australian Taxation Office published guidance covering situations when intercompany payments under software arrangements constitute taxable royalties, including definitions that incorporate a 2025 decision from Australia's highest court that sided with Pepsi in a royalty withholding tax dispute.
-
September 08, 2026
With New Tax Partner, Simpson Thacher Boosts Sports Focus
Jonathan Westreich joined Simpson Thacher & Bartlett LLP as a tax partner in its Los Angeles office, the firm announced Tuesday, deepening the firm's sports, media and entertainment bench.
-
September 08, 2026
IRS Accepting Applications To 2027 Real-Time Audit Program
The Internal Revenue Service is accepting applications for its compliance assurance process real-time audit program for 2027, the agency announced Tuesday.
-
September 08, 2026
Canada Defends Retaliatory Tariffs Against US As Necessary
Canadian Prime Minister Mark Carney defended Canada's retaliatory tariffs against the U.S. as they went into effect Tuesday, saying they are needed to protect Canadian workers and industries from President Donald Trump's latest trade war action.
-
September 08, 2026
DC Circ. Affirms Injunction Against IRS-ICE Data Sharing
The D.C. Circuit affirmed a lower court's preliminary injunction Tuesday barring the IRS from sharing taxpayer data with immigration authorities, finding that the coalition challenging the deal has standing and that the arrangement likely violates the law.
-
September 08, 2026
Biotech Company Pays £7.4M To Settle Russia Export Breach
The U.K. arm of an international genome sequencing company has paid a record £7.4 million ($10 million) for breaching export controls after it admitted to supplying sanctioned goods to Russia, HM Revenue & Customs said Tuesday.
-
September 08, 2026
HMRC Sets Out £70K Cap In Loan Charge Tax Settlements
HM Revenue & Customs set out new guidance for the U.K.'s loan charge settlement scheme, including a five-step calculation, a cap of £70,000 ($94,600) on discounted payments and a time limit for taxpayers.
-
September 08, 2026
HMRC Issues Post-Brexit Duty-Free Changes For Alcohol
Britain's tax authority said Tuesday that it's changing duty-free allowances on alcohol for travelers entering the U.K. starting in October as part of post-Brexit measures to simplify rules.
-
September 08, 2026
EU Figure Defends Tax Data Guards Amid Exchange Concerns
Amid criticism that taxpayer privacy is not sufficiently protected, a European Union tax official said Tuesday that the bloc has strong measures in place to address data-protection breaches and protect taxpayers, such as the suspension of information sharing between member states.
-
September 07, 2026
Healey Won't Rule Out Tax Hikes Despite Business Demands
Chancellor John Healey declined on Monday to rule out tax hikes in the autumn Budget statement despite demands from industry groups to reduce the fiscal pressure on businesses.
-
September 07, 2026
EU Nations Fear Digital Tax Backlash Ahead of Budget Crunch
A number of European Union countries oppose the inclusion of a bloc-wide digital services tax in the EU's long-term budget because of its potential to aggravate geopolitical tensions, according to a Council of the European Union document seen by Law360 on Monday.
-
September 04, 2026
4 Books Transfer Pricing Economists Think You Should Read
What do transfer pricing experts — economists, specifically — do in the summer? In July, many of them attend the National Association for Business Economics' annual transfer pricing symposium and discuss their favorite books with Law360 during the coffee breaks. Others were kind enough to do it during their regular work hours. Here, Law360 looks at four of their picks.
-
September 04, 2026
Pfizer Can't Cut Ala. Tax With Shuffled Loans, Court Affirms
Pfizer cannot reduce its Alabama corporate income tax liabilities by deducting $658 million in interest payments made to an Irish affiliate that shuffled them to Luxembourg affiliates as tax-free dividends, the Alabama Court of Civil Appeals said Friday, affirming a lower court's decision.
-
September 04, 2026
Hong Kong And Slovenia Sign Tax Treaty
Hong Kong and Slovenia signed a tax treaty Friday that would slash withholding tax rates for Hong Kong residents, according to the Inland Revenue Department.
-
September 04, 2026
4th Circ. Affirms $2.9M IRS Fine For Unreported Accounts
The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclose offshore accounts to the IRS.
-
September 04, 2026
Singapore's Tax Take Rises To $77B, Driven By Biz Tax
Singapore collected 97.3 billion Singapore dollars ($76.8 billion) in tax revenue during its 2025-26 fiscal year, about 9.4% more than the previous cycle, driven by corporate income tax, the country's Inland Revenue Authority said Friday.
-
September 04, 2026
BlueCrest Ruling Sparks Tax Uncertainty For UK Firms
The U.K. Supreme Court's recent ruling that fund managers are taxable as employees rather than partners injects considerable uncertainty into the financial services industry, with companies potentially facing increased scrutiny from tax authorities and less predictable tax obligations.
-
September 04, 2026
Spain Calls For EU Energy Firm Tax To Fund Climate Action
Spain called on the European Union to consider a levy on the profits of oil and gas companies to fund the region's response to the climate crisis, according to a letter and policy paper seen Friday by Law360.
-
September 04, 2026
EU Countries Bristle At Tax Avoidance Rule Proposal
European Union member states are concerned that proposed changes to anti-tax avoidance rules, such as those that relate to how much interest companies can deduct from taxable profits, may result in revenue losses and an increased risk of tax abuse, EU officials told Law360 on Friday.
-
September 03, 2026
Canadian Group Can't Blend Insurance Businesses' Income
A fraternal benefit society cannot blend its life insurance and accident insurance businesses for tax purposes, Canada's Federal Court of Appeal said, setting aside a lower court's decision.
-
September 03, 2026
Australia Floats Bill For 30% Min. Tax On Discretionary Trusts
Australia is seeking feedback on a bill that would create a 30% minimum tax on discretionary trusts to better align tax rates on trust income and employment income, the Department of the Treasury said.
-
September 03, 2026
Firm Must Give Client Docs To Tax Agency, Canada Court Says
A Toronto-based accounting firm must hand over client information to the Canada Revenue Agency, a Canadian appeals court ruled, holding that a lower court erred in giving the firm "a second kick at the can" in fighting to withhold documents.
-
September 03, 2026
EU Council OKs Bloc Customs Modernization Program
A suite of changes aimed at modernizing the European Union's customs administration to help it handle the e-commerce boom is on the precipice of implementation after the Council of the EU approved them Thursday, teeing up a final vote in the European Parliament.
Expert Analysis
-
What Ethics Rules Say On Atty Discipline For Online Speech
Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.
-
2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers
Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
-
Junior Attys Must Beware Of 5 Common Legal Brief Mistakes
Excerpt from Practical Guidance
Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
-
Power To The Paralegals: How And Why Training Must Evolve
Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.
-
5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.
-
Evaluating The Current State Of Trump's Tariff Deals
As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.
-
How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.
-
Preserving Refunds As Tariffs Await Supreme Court Weigh-In
In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.
-
Writing Musicals Makes Me A Better Lawyer
My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.
-
Adapting To Private Practice: From Va. AUSA To Mid-Law
Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.
-
7 Document Review Concepts New Attorneys Need To Know
For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.
-
Agentic AI Puts A New Twist On Attorney Ethics Obligations
As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.
-
Opportunity Zone's Future Corp. Tax Benefits Still Uncertain
Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.