International

  • 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.

  • January 07, 2026

    IRS Outlines Process For PFICs Seeking Retroactive Elections

    The Internal Revenue Service set out requirements Wednesday for passive foreign investment corporations seeking rulings to allow them to make retroactive qualified electing fund elections.

  • January 06, 2026

    IRS Appeals Pause Of ICE Info-Sharing Agreement

    The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.

  • January 06, 2026

    Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules

    A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasion that would justify the regulations.  

  • January 06, 2026

    Thai Cabinet OKs Changes To Aid Satisfying Global Min. Tax

    Thailand's Cabinet has approved draft legislation aimed at helping companies comply with the 15% global minimum tax, the country's tax authority said.

  • January 06, 2026

    Uber Changes UK Contracts Over New Minicab VAT Rules

    Uber has changed its contracts with its British drivers to reclassify itself as an agent, a move that will save it from collecting value-added tax on fares, just before the U.K.'s overhaul of tax rules for the minicab sector took effect.

  • January 06, 2026

    Ireland Offers Europe's First Tax Break For Unscripted Shows

    Ireland is offering a corporate tax credit for unscripted productions that promote Irish and European culture, the Department of Finance said, noting that the initiative is the first of its kind in Europe.

  • January 06, 2026

    Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team

    After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on the tax elements of mergers and acquisitions.

  • January 05, 2026

    Md. Railway Distributor Exec Sued Over Alleged Asset Looting

    Chinese railway equipment manufacturer Anyang Railway Equipment Co. Ltd. has filed suit in Maryland federal court, claiming the sole executive and majority shareholder of a railway distribution company, in which Anyang is also a shareholder, looted corporate assets for personal gain and excluded Anyang from management decisions, among other things.

  • January 05, 2026

    EU Sets Default Emission Levels For Carbon Border Tax

    The European Union released default levels of greenhouse gas emissions that importers must use to calculate liabilities for the newly enforced carbon border adjustment mechanism when they lack reliable information on the emissions associated with producing covered products.

  • January 05, 2026

    Countries Reach Deal To Exempt US From Pillar 2 Tax

    Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.

  • January 05, 2026

    ECJ To Mull Parent-Subsidiary Directive's Tax Impact

    The European Union's top court will rule on the tax implications of the EU's parent-subsidiary directive for a loss-making company in Germany following a request from the country's finance court, according to a Monday notice.

  • January 05, 2026

    Gibson Dunn Adds Sidley Tax Pro In Silicon Valley

    Gibson Dunn & Crutcher LLP announced Monday that it has bulked up its tax practice group with a partner in Palo Alto, California, who previously co-led the global tax practice and headed up the West Coast tax group at Sidley Austin LLP.

  • January 02, 2026

    Busy DOJ Tax Atty Seeks More Time In 7th Circ. AbbVie Case

    A U.S. Department of Justice tax attorney asked the Seventh Circuit on Friday for another extension to file an opening brief in a dispute over AbbVie's $1.6 billion payment to an Irish biotechnology company, citing staffing shortages and internal procedural requirements.

  • January 02, 2026

    IRS Floats Updates To Fee Paid By Brand Drugmakers

    The Internal Revenue Service floated updates to regulations governing how branded prescription drug manufacturers or importers should calculate an annual fee established by the Affordable Care Act, a move the agency said aims to incorporate changes in drug discount programs and clarify tax reporting.

Expert Analysis

  • Evaluating The Current State Of Trump's Tariff Deals

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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.

  • How GILTI Reform Affects M&A Golden Parachute Planning

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    Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.

  • Demystifying The Civil Procedure Rules Amendment Process

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    Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.

  • Parenting Skills That Can Help Lawyers Thrive Professionally

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    As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.

  • Trump Tax Law's Most Impactful Energy Changes

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    The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.

  • Adapting To Private Practice: From Texas AUSA To BigLaw

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    As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.

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