International

  • June 17, 2026

    Tax Court Won't Rethink Basis Ruling Against Partnership

    A U.S. Tax Court judge said Wednesday that he won't reconsider his ruling that a company electing to be treated as a disregarded entity and attempting to pay for interest in a partnership with a promissory note from its parent can't claim a basis in the partnership.

  • June 17, 2026

    Varian Owes $7.2M After Deduction Limited, Tax Court Says

    Varian Medical Systems owes more than $7.2 million to the IRS as a result of the U.S. Tax Court limiting its deemed dividends deduction, the court said, accepting an agreement reached between the parties.

  • June 17, 2026

    Danish Financier Denied Tax Appeal For Missing Deadline

    A Danish financier and his company can't appeal a decision over a tax bill of over £866,000 ($1.2 million) despite his claim that they face a 200% tax rate, a London tribunal ruled, saying he had no good reason for missing a previous appeal deadline.

  • June 17, 2026

    Insurance Co.'s $1.35B Tax Fight Sent To Nova Scotia Court

    The Tax Court of Canada declined to hear Canadian revenue authorities' bid to include over CA$1.9 billion ($1.35 billion) worth of shares in a life insurance company's taxable capital, holding that jurisdiction belongs to a Nova Scotia court.

  • June 17, 2026

    VAT Break For Credit Management Has Limits, EU Court Says

    The European Union's value-added tax exemption for managing credit doesn't apply to management services provided by an entity that granted, transferred and continued managing the credit, an EU court said Wednesday in deciding questions for a Finnish bank's tax challenge.

  • June 17, 2026

    Hong Kong Tightens Bank Rules For Tax Info Exchanges

    Hong Kong lawmakers adopted a bill Wednesday to tighten requirements on financial institutions pursuant to the automatic exchange of information between tax authorities, building off suggestions made during a peer review of the jurisdiction's legal framework, the Inland Revenue Department said.

  • June 17, 2026

    HMRC Wins Top Court Case On Taxation Of Partnership Pay

    Britain's top court ruled on Wednesday that deferred pay distributed to individual partners at a foreign exchange trading firm must be taxed as income, giving a win to HM Revenue and Customs in its challenge to the company's remuneration structure.

  • June 16, 2026

    2nd Circ. Won't Let Man Reverse Tax Plea Over Bad Advice

    The Second Circuit issued a summary order Tuesday affirming the conviction of a Connecticut man who pled guilty to tax crimes, disagreeing that allegedly misleading advice from trial attorneys about the immigration implications of his plea warranted his withdrawing it.

  • June 16, 2026

    Israeli Law Firm Has No Case Against GILTI Regs, Gov't Says

    An Israeli law firm cannot challenge IRS regulations implementing the 2017 tax law's global intangible low-taxed income regime largely because any connected compliance burden is borne by its U.S. shareholder, not the firm itself, the government told a D.C. federal court.

  • June 16, 2026

    Arizonan Owes $1.9M For Unreported Accounts, 9th Circ. Says

    An Arizona man is on the hook for $1.9 million in penalties for undisclosed foreign bank accounts, the Ninth Circuit ruled, rejecting his contention that a district court mishandled the process for facilitating the IRS' recalculation of the amount.  

  • June 16, 2026

    KC Defends Gardener Trust Deal In £2M Evasion Trial

    A senior barrister accused of cheating the public purse out of almost £2 million ($2.7 million) argued Tuesday that his former gardener perfectly understood that an agreement to be compensated for his services via a trust was not binding.

  • June 16, 2026

    Revamp Of EU Tax Rules Set To Change Reporting Hallmarks

    A shake-up of European Union rules on tax information sharing is set to change criteria that trigger reporting obligations, notably tweaking hallmarks of potentially aggressive tax arrangements, according to draft revisions seen Tuesday by Law360.

  • June 16, 2026

    EU Parliament Approves Trade Deal With US

    European Union lawmakers voted Tuesday to approve legislation implementing the bloc's safeguard-bolstered trade deal with the U.S. founded on a series of tariff cuts, moving one step closer to implementation that is expected before the end of the month.

  • June 16, 2026

    UK Seeks Input On New Transfer Pricing Reporting Rules

    The British government is seeking feedback from businesses and other stakeholders on draft rules for new reporting requirements for international controlled transactions, HM Revenue & Customs said Tuesday.

  • June 15, 2026

    HMRC Can Levy Exit Tax On Trust's £142M Gains, Court Rules

    Britain's tax authority can collect an exit tax charged on over £142 million ($190 million) in gains from a real estate company and on over £330,000 in assets from a family trust, provided that the tax is paid in a five-year installment plan, a London court ruled.

  • June 15, 2026

    Justices Won't Review Trump's First-Term China Tariff Hikes

    The U.S. Supreme Court refused Monday to review a case challenging tariffs that President Donald Trump installed and increased on Chinese goods during his first term.

  • June 15, 2026

    Dutch Gov't Rejects National Parcel Handling Fee

    The Dutch government rejected a request from lawmakers to introduce a national handling fee for parcels and will instead rely on measures at the European Union level.

  • June 15, 2026

    Disqualified Director Jailed For £3M Fraud, Money Laundering

    A company director has been sentenced to four years in prison for diverting more than £3 million ($4 million) through an insolvency fraud and money laundering scheme, the Insolvency Service said.

  • June 15, 2026

    KC Says He Was Entitled To Cut Tax Bill In £2M Evasion Case

    A senior barrister accused of cheating the public purse out of almost £2 million ($2.7 million) told a court on Monday that he was "morally entitled" to pursue a strategy to reduce his tax liability.

  • June 12, 2026

    Global Minimum Tax Was A Bad Bargain, Tax Pros Say

    The global minimum tax known as Pillar Two had the paradoxical goal of increasing countries' taxing power by having them cede some of their authority to set corporate rates — and ultimately would have hurt both wealthy and developing nations, tax specialists said at a conference Friday.

  • June 12, 2026

    Partnership Owes No Taxes On £13M Transfer, Court Says

    A U.K. appeals court ruled Friday against revenue authorities' bid to collect taxes on approximately £13 million ($17.4 million) that affiliated trusts transferred to a partnership after selling their shares in an industrial business.

  • June 12, 2026

    4 Questions As Gov't Appeals Illegal Tariff Refund Suit

    The government's appeal of an order requiring immediate refunds for tariffs that were deemed illegal by the U.S. Supreme Court earlier this year is the latest obstacle for importers forced to stall investments in new products and brace for a longer wait for their refunds in response.

  • June 12, 2026

    Biz Groups Back Liberty Global In $2.4B Tax Substance Fight

    The Tenth Circuit should reconsider its decision denying telecommunications company Liberty Global a $2.4 billion income deduction, the U.S. Chamber of Commerce and other groups said, arguing the court excessively broadened a rule that is meant to disallow tax benefits in limited situations.

  • June 12, 2026

    EU States Aim To Expand Carbon Border Tax Downstream

    The European Union's council of ministers wants to expand the bloc's tax on emissions-intensive imports from raw materials to a selection of downstream products containing steel and aluminum while also closing loopholes, according to a proposal made Friday.

  • June 12, 2026

    Danish Justices Allow 5 Years For Withholding Tax Refunds

    Denmark must provide a five-year window for nonresidents to claim refunds on withholding taxes charged for dividends or royalties, the country's Supreme Court said in a decision involving overpayments pursuant to tax treaties.

Expert Analysis

  • Alpine Skiing Makes Me A Better Lawyer

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    Skiing has shaped habits I rely on daily as an attorney — focus, resilience and the ability to remain steady when circumstances shift rapidly — and influences the way I approach legal strategy, client counseling and teamwork, says Isaku Begert at Marshall Gerstein.

  • What A Court Doc Audit Reveals About Erroneous Filings

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    My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.

  • Getting The Most Out Of Learning And Development Programs

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    Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.

  • AI Presents A Make-Or-Break Moment For Outside Counsel

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    The rapid adoption of artificial intelligence by corporate legal departments is forcing a long-overdue reset of the relationship between inside and outside counsel, and introducing a significant opportunity to shed frustrating inefficiencies and strengthen collaboration for firms willing to embrace the shift, says Intel Chief Legal Officer April Miller Boise.

  • 8 Tariff Refund Questions For Restructuring Professionals

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    For restructuring and turnaround professionals, seeking refunds following the U.S. Supreme Court's recent decision invalidating tariffs imposed under the International Emergency Economic Powers Act raises several questions about how to capture legitimate recoveries while protecting an enterprise from the consequences of its own history, says Jonny Frank and Laura Greenman at StoneTurn, and Andrew Popescu at Province.

  • 5 Tips For Navigating Your Firm's All-Attorney Summit

    Excerpt from Practical Guidance
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    Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.

  • The Benefits Of Choosing A Niche Practice In The AI Age

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    As artificial intelligence becomes increasingly accessible, lawyers with a niche practice may stand out as clients seek specialized judgment that automation cannot replicate, but it is important to choose a niche that is durable, engaging and a good personal fit, says Daniel Borneman at Lowenstein Sandler.

  • Tax Court Ruling Signals Cross-Border Loan Scrutiny

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    The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.

  • How Banks Can Apply FinCEN Beneficial Ownership Relief

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    A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.

  • Aligning Microsoft Tools With NYC Bar AI Recording Guidance

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    The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.

  • 5 Different AI Systems Raise Distinct Privilege Issues

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    A New York federal court’s recent U.S. v. Heppner decision, holding that a defendant’s use of Claude was not privileged, only addressed one narrow artificial intelligence system, but lawyers must recognize that the spectrum of AI tools raises different confidentiality and privilege questions, says Heidi Nadel at HP.

  • AI-Assisted Arbitration Needs Safeguards To Ensure Fairness

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    As tribunals and arbitral institutions increasingly use artificial intelligence tools in their decision-making processes, ​​​​​​​clear disclosure standards and procedural safeguards are necessary to ensure that efficiency gains do not erode the fairness principles on which arbitration depends, says Alexander Lima at Wesco International.

  • AI-Generated Doc Ruling Guides Attys On Privilege Risks

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    A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.

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