International

  • March 12, 2025

    Starbucks' Sourcing Aided $1.3B Low-Tax Profits, Report Says

    Starbucks leveraged its private certification program for coffee growers to boost profits transferred almost tax-free from Switzerland to the Netherlands to the U.K., amounting to an estimated $1.3 billion between 2011 and 2021, according to a report from a union-funded nonprofit organization.

  • March 12, 2025

    Tariffs Prompt Chipmakers To Look At Manufacturing Moves

    The U.S. semiconductor industry is considering moving manufacturing operations to the U.S. and elsewhere as a tariff-mitigation strategy with President Donald Trump threatening to levy the sector and its supply chains, professionals told Law360.

  • March 12, 2025

    EU E-Commerce Group Calls For Extended DST Moratorium

    The expiration of an agreement pausing implementation of digital services taxes comes as the entirety of the OECD's two-pillar agreement on international taxes leaves impacted businesses in uncertain waters, a European Union business group said in a letter, seeking an extension of the moratorium.

  • March 12, 2025

    EU Targets US Goods In Response To Trump's Tariffs

    The European Commission said Wednesday that it will impose tariffs on American goods imported into the European Union in response to U.S. tariffs placed on EU steel and aluminum exports.

  • March 12, 2025

    Spain Referred To CJEU Over Nonresident Tax Treatment

    Spain will have to face the Court of Justice of the European Union over what the European Commission said is a discriminatory capital gains tax regime because of a deferral available to residents that is not available to nonresidents.

  • March 12, 2025

    HMRC To Reward Whistleblowers Who Expose Tax Fraud

    Insiders who tip off investigators to serious tax avoidance by large companies and rich elites will be paid a cut of any money the U.K. tax enforcer claws back under a new policy proposed by the government.

  • March 11, 2025

    Canada's Incoming PM Pledges To Kill Capital Gains Tax Hike

    Canada's newly elected Prime Minister-designate Mark Carney said during his election victory speech that he would spike a controversial proposed increase to the country's capital gains tax, according to local media.

  • March 11, 2025

    Trump, Ontario Back Down After Two-Day Trade Flare-Up

    President Donald Trump called off additional tariffs on Canadian steel and aluminum Tuesday after the Ontario government dropped a briefly imposed surcharge on electricity exports, the White House told Law360 on Tuesday evening. 

  • March 11, 2025

    Retailer Fights US On Overriding Jury In $11.6M FBAR Case

    A federal jury in Hawaii was justified in finding that an international businessman hadn't willfully failed to report his foreign bank accounts in an $11.6 million dispute, and the U.S. government is not entitled to an overruled verdict or new trial, he told the court.

  • March 11, 2025

    Russia Says Guinea Ruling Backs Dismissal In $5B Award Suit

    A recent D.C. federal court decision supports the Russian Federation's bid to dismiss an arbitration enforcement action stemming from a tax dispute with Yukos Capital Ltd., Russia told the same court.

  • March 11, 2025

    12 Govs. Assert States' Sovereignty Against CTA In 5th Circ.

    A dozen Republican governors, led by Georgia Gov. Brian Kemp, urged the Fifth Circuit to maintain a nationwide block of enforcement of the Corporate Transparency Act, arguing the law undermines the traditional authority states have to regulate businesses.

  • March 11, 2025

    Carlton Fields Tax Ace Jumps To Trenam Law In Fla.

    Florida's Trenam Law has added a past chair of the tax section of the state bar after her 25-year stint at Carlton Fields PA.

  • March 11, 2025

    EU Council Approves 'Decluttering' Tax Agenda

    The Council of the European Union said Tuesday that it has approved the "decluttering" agenda to simplify tax legislation across the bloc and cut red tape to make the system more competitive.

  • March 11, 2025

    EU Council Agrees On Reporting Rules To Back Min. Corp. Tax

    The Council of the European Union said Tuesday it has reached an agreement to enact reporting rules to support the 15% global minimum corporate tax rate across the EU.

  • March 11, 2025

    EU Council Adopts Digital VAT Reform Package

    The Council of the European Union said Tuesday that it has adopted reforms to adapt the EU's value-added tax regime to the digital economy.

  • March 10, 2025

    Tariff Shifts Creating Compliance Chaos For Energy Cos.

    The unpredictability of President Donald Trump's tariff maneuvers is challenging energy companies' ability to comply with fluctuating mandates and making tariff violations more likely.

  • March 10, 2025

    EU Tax Revenue Hits €6.7T, Lowest GDP Share Since 2011

    While European Union members' collective tax revenue was up nearly 5% to more than €6.7 trillion ($7.3 trillion) in 2023, tax revenue as a share of gross domestic product in the bloc was the lowest it has been since 2011 thanks to inflation, a news release said Monday.

  • March 10, 2025

    Ex-Credit Suisse Client Pleads Guilty To Hiding $90M

    A Colombian-American businesswoman and former Credit Suisse client pled guilty Monday in Florida federal court to conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.

  • March 10, 2025

    Feds Sue FDIC For $1.9M For First Republic Tax Bill

    The U.S. government sued the Federal Deposit Insurance Corp. in D.C. federal court as receiver for the failed First Republic Bank, alleging the bank understated its withholding tax for U.S.-sourced income of foreigners and now owes almost $2 million to the federal government.

  • March 10, 2025

    Treasury's CTA Halt Doesn't Justify Block, Feds Tell 5th Circ.

    The U.S. Treasury Department halting enforcement of the Corporate Transparency Act on domestic entities doesn't add justification to a nationwide block on the law because it's a valid exercise of Congress' powers to regulate commerce, taxes, foreign affairs and national security, the U.S. government told the Fifth Circuit.

  • March 10, 2025

    Court Affirms FBAR Penalties Against Estate, Not Widow

    The estate of a man who failed to report his Swiss bank accounts is liable for tax penalties of at least $2 million, an Idaho federal court determined, finding the man's widow off the hook.

  • March 10, 2025

    Tax Pro Rejoins Norton Rose From Reed Smith In Houston

    Norton Rose Fulbright announced Monday that it has bulked up in the face of increased demand in the corporate transactions space with the return of a tax partner in Houston who came aboard from Reed Smith LLP.

  • March 10, 2025

    Int'l Tax Changes Can Help Gender Equality, Economists Say

    Countries could address persistent gender gaps in tax systems by overhauling their approach for wealthy individuals and multinational corporations, according to a group of economists, who said low female shares of capital income and wealth currently limit related tax benefits.

  • March 10, 2025

    German Election Raises Doubts About Pillar 2 From Tax Pros

    The new German government could end up abandoning the international corporate minimum tax agreement known as Pillar Two because of rising competition between the U.S. and Europe, experts told Law360.

  • March 07, 2025

    Mauritius Government Lawyer Joins CMS Affiliate

    CMS said an attorney with more than a decade of experience as a Mauritius government lawyer has joined CMS Prism, the firm's Mauritian affiliate.

Expert Analysis

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

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