International

  • June 03, 2025

    USTR Extends Exclusions From 2018 China Tariffs

    The Office of the U.S. Trade Representative has extended tariff exclusions for certain products from China under a set of 2018 trade measures aimed at what the U.S. described as Beijing's restrictive intellectual property rules.

  • June 03, 2025

    Irish Court Says US Co.'s Irish Units Not Owed Treaty Benefits

    Three Irish subsidiaries cannot benefit from the U.S.-Ireland tax treaty's provision of equally favorable treatment between U.S. and Irish residents because their ultimate parent entity, a Delaware financial firm, is disregarded for U.S. tax purposes, Ireland's Court of Appeal said in a judgment.

  • June 03, 2025

    Lawyer Given Suspended Sentence In Germany Over Cum-Ex

    A business lawyer who was partly responsible for running a €428 million ($488 million) tax fraud scheme was issued a suspended sentence of almost two years, according to a verdict Tuesday in a Bonn court.

  • June 03, 2025

    The Law360 400: A Look At The Top 100 Firms

    A rebound in client work sent the nation’s largest law firms into growth mode last year, driving a wave of hiring, mergers and strategic moves that reshaped the top tier of the Law360 400. Here's a preview of the 100 firms with the largest U.S. attorney headcounts.

  • June 03, 2025

    Ex-Pandora Boss To Blame For His Own Tax Bill, Adviser Says

    A tax adviser has denied exposing the former president of jewelry giant Pandora, Peter Andersen, to significant liabilities tied to a €2.2 million ($2.5 million) French property deal, saying that any losses were caused by the ex-chief's deliberate and independent decisions.

  • June 02, 2025

    Montana Tribal Tariff Dispute Will Stay In US Trade Court

    A Montana federal judge won't reconsider an order to transfer a challenge to President Donald Trump's Canada tariff orders by members of the Blackfeet Nation to the U.S. Court of International Trade, saying the CIT has historical jurisdiction over claims by tribal members on import and duty-related actions.

  • June 02, 2025

    White House Asks DC Circ. To Halt Tariff Injunction

    The White House on Monday asked the D.C. Circuit to hit pause on a lower court ruling that found President Donald Trump's tariffs unlawful, arguing the "legally indefensible preliminary injunction" would impede sensitive trade negotiations if left unchecked.

  • June 02, 2025

    IRS Issues Interim Regs To Simplify Corp. AMT Determination

    The Internal Revenue Service released temporary regulations Monday that offered a simplified method for large companies seeking to determine whether the 15% corporate alternative minimum tax applies to them, as well as penalty relief for those that underpaid the levy this year.

  • June 02, 2025

    Bahamas Looks To Update Corp. Minimum Tax Rules

    The Bahamas is looking for input on changes to its adoption of the OECD's minimum corporate income tax on large multinationals in order to better align it with updated standards, among other goals, the country said.

  • June 02, 2025

    Finland Plans Further Tweaks To Soft Drink Tax After EU Input

    While the European Commission broadly found that Finland's plan to alter its sugary drink tax to create different tiers based on sugar content didn't violate state aid rules, it called for some tweaks that the country will pursue, Finland's Finance Ministry said Monday.

  • June 02, 2025

    Halliburton Wants IRS To Release Docs In $35M Tax Dispute

    The Internal Revenue Service should be ordered to comply with Halliburton's discovery requests in a dispute over a $35 million deduction for payments the company said it made to a foreign government to protect its employees from harassment, the company told a Texas federal court.

  • June 02, 2025

    GOP Budget Adds Punitive Twist To Talks On Digital Taxes

    The House-passed budget's punitive tax hikes on companies and people from countries with digital services taxes is poised to complicate trade negotiations aimed at removing DSTs and to weaken foreign investment in the U.S., fiscal experts told Law360.

  • June 02, 2025

    Remote Workers Take German Tax Case To EU's Top Court

    The European Court of Justice said Monday it will hear the case of two taxpayers against a German regional tax authority over whether Swiss residents working remotely are taxable in Germany.

  • June 02, 2025

    CJEU Set To Hear SocGen's Case In Swedish Tax Dispute

    The Court of Justice of the European Union said Monday that it will hear the case of French banking giant Société Générale SA against the Swedish tax authority over the taxation of nonresident companies under the European treaty.

  • June 02, 2025

    OECD Releases Consolidated Text Of Data-Swap Guidance

    The Organization for Economic Cooperation and Development published consolidated text of a global reporting standard Monday to help tax administrations exchange financial information about individuals who may be trying to hide money from their tax authorities at home.

  • June 02, 2025

    IRS To Hold Hearing On Sourcing Cloud Transaction Income

    The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.

  • May 30, 2025

    US-China Trade Talks Could Resume After Stall Over Minerals

    Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.

  • May 30, 2025

    Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight

    An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.

  • May 30, 2025

    HMRC Correctly Handled Land Tax Dodge, UK Court Says

    HM Revenue & Customs followed the correct procedures to collect taxes on six individuals who attempted to dodge the U.K.'s land tax by transacting with a special purpose vehicle in Guernsey, the Upper Tribunal ruled.

  • May 30, 2025

    Isle Of Man Agrees To Work With UK Against Tax Avoidance

    Isle of Man authorities reached an agreement with the U.K. government to work together in a crackdown on promoters of tax avoidance schemes, according to a joint statement.

  • May 30, 2025

    UK Midsize Biz Owners Wary Of Risk Exposure, Report Says

    Owners and operators of midsize U.K. businesses are just as wary of risk exposure in personal taxes as they are in business taxes except under certain circumstances, according to a report commissioned by HM Revenue & Customs.

  • May 30, 2025

    Taxation With Representation: Kirkland, Cravath, Latham

    In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.

  • May 29, 2025

    DC Court Blocks Trump's Tariffs As Overreach Of Power

    The International Emergency Economic Powers Act does not empower the president to impose tariffs, the D.C. federal district court said Thursday, ruling that President Donald Trump's global levies are unlawful and barring his administration from enforcing them on two toymakers who challenged the policies.

  • May 29, 2025

    Fed. Circ. Revives Trump Tariffs As It Weighs Appeal

    The Federal Circuit temporarily reinstated President Donald Trump's global tariffs Thursday, a day after the U.S. Court of International Trade held that an emergency law did not give the president "unbounded authority" to impose the measures.

  • May 29, 2025

    Australia Outlines Compliance For Thin Capitalization Test

    The Australian Taxation Office is looking for feedback on draft compliance guidance for corporations looking to use one of its new thin capitalization tests as they relate to cross-border financing arrangements, it said Thursday.

Expert Analysis

  • An Unrestrained, Bright-Eyed View Of Legal AI's Future

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    Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.

  • Tracking The Evolution In Litigation Finance

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    Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.

  • E-Discovery Quarterly: The Perils Of Digital Data Protocols

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    Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.

  • A Cold War-Era History Lesson On Due Process

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    The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.

  • How BigLaw Executive Orders May Affect Smaller Firms

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    Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.

  • Lawsuits Shouldn't Be Shadow Assets For Foreign Capital

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    Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.

  • How To Accelerate Your Post-Attorney Career Transition

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    Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.

  • Tariffs And FCA Create Perfect Storm For Importers

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    The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.

  • US Reassessment Of OECD Tax Deal Is Right Move

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    The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.

  • Measuring And Mitigating Harm From Discriminatory Taxes

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    In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.

  • Adapting To Private Practice: From DOJ Leadership To BigLaw

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    The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.

  • How The CRE Industry Is Adapting To Tariff Uncertainty

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    Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.

  • Law Firm Executive Orders Create A Legal Ethics Minefield

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    Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.

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