International

  • October 30, 2026

    Hedge Fund Exec Fights $40M In IRS Foreign Reporting Fines

    A hedge fund manager is seeking to recover nearly $40 million in foreign account reporting penalties, telling the U.S. Court of Federal Claims that the IRS violated his due process rights and administrative rules in imposing fines linked to his bankrupt Texas tycoon father's international accounts.

  • October 30, 2026

    Brookfield Fights $4.3M Tax Bill Over Lehman Losses

    Asset management giant Brookfield is challenging a $4.3 million tax bill tied to its acquisition of a defunct Lehman Brothers unit, telling the U.S. Tax Court that the IRS incorrectly denied a deduction stemming from the Lehman affiliate's losses.

  • October 30, 2026

    EU, Canada Seal Digital Trade Deal Amid Closer Partnership

    EU and Canadian officials signed a document Friday concluding negotiations on a digital trade agreement between the two economies following a summit in Montreal where Canadian and European leaders shared new details about efforts to strengthen their economic and diplomatic ties.

  • October 30, 2026

    Countries Want OECD Plan To Tax Digital Economy

    The Organization for Economic Cooperation and Development has been tasked with creating a plan to continue work on taxing the digital economy by countries that participate in its global tax policymaking body, the organization said Friday.

  • October 30, 2026

    Buchalter Adds Tax Pro In Dallas From Jackson Walker

    Buchalter PC's rapid growth in Texas continues with the addition of a Dallas-based tax partner who came aboard from Jackson Walker LLP.

  • October 30, 2026

    2 In Merseyside Jailed Over £8.5M Teeth-Whitening VAT Scam

    Two men from Merseyside, England, who stole more than £8.5 million ($11.4 million) in tax from the sale of dangerous teeth-whitening products were sentenced to over four years each in prison, Britain's tax authority said Friday.

  • October 30, 2026

    Taxation With Representation: Kirkland, Gibson Dunn, Cravath

    In this week's Taxation with Representation, Blackstone, Bank of America, Citi and Morgan Stanley announce a financing structure to buy Broadcom artificial intelligence chips and network components for Anthropic, EQT acquires Range Resources to create a powerhouse natural gas company, and DoorDash buys Instacart.

  • October 30, 2026

    HMRC Sets Out Penalties For Promoting Tax Schemes

    HM Revenue & Customs set out new penalties for promoters of certain tax avoidance schemes in guidance published Friday.

  • October 30, 2026

    Canada Tax Court Largely Lets PE Fund Shield EY Docs

    A private equity fund can mostly use attorney-client privilege to shield documents concerning its tax strategy that were created by EY for the fund's law firm, the Tax Court of Canada said in a fight over whether an anti-avoidance rule applies to the fund's financing.

  • October 29, 2026

    German Co. Says $1.2M IRS Tax Bill Rests On Invalid Rule

    A German manufacturer challenging a $1.2 million tax bill stemming from late information filings with the IRS told the U.S. Tax Court it should be able to claim deductions and credits despite missing the statutory due date, saying the agency applied a rule that is procedurally invalid under federal law.

  • October 29, 2026

    US Expatriations In Q3 Down 16% From Last Year, IRS Says

    The number of people who lost or renounced their U.S. citizenship totaled more than 1,300 in the third quarter of 2026 as logged by the U.S. Department of the Treasury, down about 16% year over year and 25% from the previous quarter, the IRS said Thursday.

  • October 29, 2026

    Frasers Unit Loses £5.6M VAT Dispute Over Marketing Photos

    A Frasers Group unit lost its bid to overturn assessments that it owed value-added tax of £5.6 million ($7.4 million) when a London court ruled that the company's marketing photos were linked to taxable retail sales and consumer credit.

  • October 29, 2026

    Tax Consultancy Asks 5th Circ. To Kill Microcaptive Rule

    The IRS never published data showing that microcaptive transactions pose a potential for tax avoidance to justify a rule making companies and advisers report them as "transactions of interest," a tax consultancy seeking the rule's demise told the Fifth Circuit.

  • October 29, 2026

    Wyo. Court Flags AI Use In Defamation Case Against Tax Atty

    A Wyoming federal judge threatened sanctions against an exiled U.K. financial services provider who is suing a tax attorney for defamation, noting the businessman's filings indicate the use of artificial intelligence and potential perjury regarding his residency status.

  • October 29, 2026

    FCA Urged To Probe Possible Leak Of Bank-Tax Budget Plans

    The parliamentary Treasury Committee asked HM Treasury and the Financial Conduct Authority on Thursday to investigate whether confidential details of the government's planned bank tax increase were improperly disclosed before the Budget speech on Wednesday.

  • October 28, 2026

    Canada Court Won't Block Plan To Pull Group's Charity Status

    A Canadian appeals court denied an organization's request to halt revenue collectors' plan to revoke its charitable status, holding that the group failed to show it would suffer irreparable harm if the agency publicly disclosed the revocation.

  • October 28, 2026

    Pitney Bowes Denied Interest In Repatriation Tax Fight

    The IRS doesn't owe interest to Pitney Bowes for overpaid 2017 federal income taxes, the U.S. Court of Federal Claims held, finding the agency was allowed to apply a chunk of the overpayment to the global shipping and logistics company's repatriation tax liability.

  • October 28, 2026

    Microsoft Seeks $115M NJ Refund Over GILTI Apportionment

    New Jersey unconstitutionally apportioned Microsoft's global intangible low-taxed income by failing to account for the activities of foreign entities that generated those earnings, the company argued in asking the state tax court to award it a $114.6 million corporate tax refund.

  • October 28, 2026

    UK Director Owes Tax On Shuffled Debt, Tribunal Affirms

    The moving of a roughly £513,000 ($684,000) loan a U.K. director owed his company to its parent holding company still counts as a release of the loan, a London court affirmed Wednesday, sticking the director with an additional £195,000 in income tax.

  • October 28, 2026

    Exec Can't Shake AU$17M Tax Settlement, Court Says

    A director cannot appeal his liability for judgment under a roughly AU$17 million ($12 million) settlement deed linked to tax fraud allegations against his companies because his challenge had no merit, was filed late and lacked supporting evidence, the Supreme Court of New South Wales said Wednesday.

  • October 28, 2026

    ABA Urges Treasury To Drop 1040 Citizenship Question

    The American Bar Association's Tax Section urged the U.S. Department of the Treasury to remove a proposed citizenship status question from individual tax returns, saying it has no stated purpose and is not connected to any tax-related eligibility determination.

  • October 28, 2026

    Judge Sides With Feds In Pair's $1.6M Tax Penalty Dispute

    A formerly married couple are not entitled to claim a refund of roughly $1.6 million for tax penalties related to a foreign trust, a Pennsylvania federal magistrate judge ruled, finding the court lacks jurisdiction because they failed to demonstrate they properly filed a refund claim.

  • October 28, 2026

    CBP Clears Nearly 16M Imports In 3rd Tariff Refund Phase

    In just over two weeks, U.S. Customs and Border Protection has cleared nearly 16 million more imports as part of the third phase of its tariff refund system, according to a declaration filed by a CBP official at the U.S. Court of International Trade.

  • October 28, 2026

    Nigerian Man Extradited For $100 Million IRS Refund Scheme

    A Nigerian man facing charges that he obtained more than $100 million in tax refunds fraudulently by posing as tax professionals and taxpayers was arraigned after being extradited from Benin, the U.S. Department of Justice said.

  • October 28, 2026

    Pillar 2 Minimum Tax Funds Could Finance EU Budget

    A coming draft of the European Union's next long-term budget could propose using Pillar Two funds as a revenue source to finance the bloc's spending priorities, three EU officials told Law360 on Wednesday.

Featured Stories

  • 3 Ways UK May Reshape Taxes In Budget

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    The U.K.'s Labour government is set to announce its fiscal agenda in its autumn budget Wednesday, and many experts predict higher taxes on banks and a crackdown on tax dodgers. Here, Law360 highlights three areas to watch for tax changes in the budget.

  • How The Midterms Are Likely To Shape Tax Policy

    Natalie Olivo

    While the outcome of the midterm elections won't change tax policy overnight, the winning party should at the very least have the chance to signal its priorities and work on bipartisan legislation that could become law even in a divided government. Here, Law360 breaks down different tax policy scenarios that could come from the elections.

  • EU Top Court Poised To Clarify Cross-Border Tax Rules

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    The European Union's highest court is set to issue a ruling Thursday that's expected to provide clarity on whether authorities can deny a cross-border withholding tax exemption on the basis of tax abuse even when dividends are sent to a genuine parent company rather than a shell company.

Expert Analysis

  • How AI Could Help Judges Spot Their Own Biases

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    In close cases where there’s room for discretion, artificial intelligence could challenge judges’ implicit biases by running counterfactual tests at scale — but any judicial use of such tools would need guardrails, say Arnold Peter at Peter Law and Nancy Rapoport at University of Nevada.

  • 3 Strategies To Reduce AI Sycophancy In Legal Work

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    The tendency of generative artificial intelligence models to tell users what they want to hear can reinforce attorneys’ confirmation bias when testing the strength of arguments, and it can’t simply be prompted away — but a few practices can help mitigate it, says Michael Ott at Ice Miller.

  • DOJ Directive Gives Contractors A Fraud Risk Road Map

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    For government contractors, the 10 factors described in the U.S. Department of Justice's recent corporate fraud enforcement directive function as a de facto scoring rubric for internal audits that mirrors what prosecutors will prioritize, say attorneys at Spencer Fane.

  • Tariffs Could Be Behind Surge In FTZ Production Filings

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    As tariffs reshape production sourcing decisions, manufacturers are seeking foreign trade zone production authority at more than twice last year's pace, making it important to consider the potential duty and export benefits, along with review delays and restrictions that can curb savings, say attorneys at Sidley.

  • Transfer Pricing Analyses May Apply To Tariff Refunds Claims

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    Both plaintiffs and defendants in consumer class actions over tariff refunds should examine transfer pricing analyses, which can offer contemporaneous evidence as to how much of a tariff was borne in the U.S. by the importer or consumers rather than absorbed earlier in the supply chain, say economists at The Brattle Group.

  • Importer Risk Rises As AI Enters Trade Fraud Enforcement

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    The Trump administration's new data-driven and artificial intelligence-enabled push against tariff evasion raises the stakes for companies with global supply chains, making it crucial that they consider strengthening response protocols, documentation and internal reporting mechanisms, say attorneys at Cooley.

  • What Lawyers Should Know Before Accepting Crypto Payment

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    As clients increasingly request to pay legal fees, retainers and escrow funds using cryptocurrency, lawyers should consider how only a handful of state bar authorities have addressed the issue with varying ethics opinions, as well as the related questions that no authority has yet answered, says attorney Felix Shipkevich.

  • Why And How To Build A Neurodiversity-Informed Practice

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    By better understanding neurodiversity and implementing simple accommodations for clients with autism, ADHD or learning differences, attorneys can build stronger relationships with those who may otherwise struggle to obtain and benefit from legal services, while developing good habits that will benefit everyone they represent, says Ting Cheung at Sanford Heisler.

  • Why Importers Should Assess IEEPA Refund Claims Now

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    Businesses that wait for direction from U.S. Customs and Border Protection or the courts before seeking refunds of their finally liquidated International Economic Emergency Procedure Act duties in court may find them out of reach as the earliest potential limitation deadlines are approaching, says Samuel Finkelstein at LMD Trade Law.

  • AI Meeting Recaps Pose New Discovery And Privilege Risks

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    The New York City Bar Association’s recent ethics opinion, cautioning attorneys not to record nonclient conversations with artificial intelligence tools, reflects an emerging view that AI meeting recaps are now a distinct business record category, meaning counsel should set meeting-level controls and apply framework-level updates, says William Wright at Faegre Drinker.

  • Playing Bid Whist Makes Me A Better Lawyer

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    As a child, I viewed bid whist as a family tradition and a source of friendly card game competition, but as a lawyer, I see it as a tool that has helped me cultivate skills like communication, teamwork, risk assessment and composure, says Keyonn Pope at Riley Safer.

  • Md. Digital Tax Ruling Is A Road Map For Future Challenges

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    Three Maryland Tax Court rulings that recently struck down the state's digital advertising tax suggest constitutional and statutory vulnerabilities that could be used to challenge newly enacted digital services laws or legislation being considered by other states, say attorneys at Holland & Knight.

  • Calif. Bill Goes Too Far In Trying To Regulate Attorney AI Use

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    California’s first-in-the-nation act regulating how attorneys and arbitrators use generative artificial intelligence will likely soon become law, but read broadly, the provisions may dissuade lawyers from employing AI at all, thereby depriving them of key work tools, says Joshua Wurtzel at Schlam Stone.