International
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February 18, 2026
Varian Contests $1.5B IRS Bill In Tax Court
Varian Medical Systems does not owe $1.24 billion in additional taxes or $248 million in penalties the IRS assessed after the agency recharacterized the company's sales of subsidiaries in the Netherlands and Switzerland, the company told the U.S. Tax Court.
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February 18, 2026
IRS Asks Court To Deny Probe Of Improper ICE Data-Sharing
A coalition suing the IRS over its data-sharing deal with immigration enforcement authorities should not be allowed to investigate the agency's revelation that it shared some data improperly, the IRS told a D.C. federal court, saying it made the admission "in good faith."
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February 18, 2026
Glencore Says It Paid $1B To HMRC Over Tax Disputes
Mining giant Glencore told shareholders Wednesday that it paid $1 billion to the U.K.'s tax authority last year over tax disputes but is pushing to recover some of the money.
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February 18, 2026
Tax Group Of The Year: Eversheds Sutherland
Eversheds Sutherland's tax practice advised on key deals in 2025, guiding Duke Energy in securing $20 million in investment credits and aiding Verizon in avoiding $12 million in corporate franchise taxes, earning it a spot among the 2025 Law360 Tax Groups of the Year.
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February 18, 2026
8th Circ. Misread Law In 3M's $24M Case, Tax Prof Says
The Eighth Circuit misconstrued the statute underpinning transfer pricing regulations when it blocked the IRS from allocating nearly $24 million of 3M Co.'s Brazilian income, a tax professor said in backing the agency's bid for a rehearing by the full court.
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February 18, 2026
Australia Seeks Input On Global Minimum Tax Amendments
Australia is looking for input on changes to its global minimum tax legislation aimed at implementing Organization for Economic Cooperation and Development guidance, including tweaks to how its domestic minimum tax applies to stateless entities and joint ventures, the Department of the Treasury said.
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February 17, 2026
No Fraud By IRS In FOIA Over $18M Tax Case, DC Circ. Says
The Internal Revenue Service did not commit fraud when it said records were missing amid Freedom of Information Act litigation related to an $18 million tax case, the D.C. Circuit said Tuesday, denying claims made by the estate of a man whose offshore businesses were raided.
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February 17, 2026
Ex-IRS Official Drops Suit Over Private Info Leak
The former commissioner of the IRS' Large Business and International Division asked a D.C. federal court to drop her suit accusing the agency of unlawfully leaking information on her employment status to the media, according to a filing.
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February 17, 2026
OECD Updates Tool For Amount B And Issues Guidance
The Organization for Economic Cooperation and Development released an updated tool Tuesday for making calculations under its transfer pricing method known as Amount B and issued guidance on frequently asked questions.
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February 17, 2026
EU Seeks Feedback For Bill To Streamline Corporate Tax Laws
The European Union is seeking feedback on how to streamline its corporate tax laws in a bill slated to be proposed in the second quarter of the year, the bloc's executive branch said.
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February 17, 2026
Ireland Looks At Expanding Coverage Of R&D Tax Credit
Ireland is looking at expanding the coverage of its research and development tax credit, including by revising qualifying expenditures, subcontracting rules and capital expenditures, according to a report by the country's finance ministry.
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February 17, 2026
Unregistered Tax Advisers May Be Blocked, HMRC Warns
HM Revenue & Customs may block intermediaries who fail to register as a tax adviser, including for corporate and personal tax matters, cutting them off from services, the tax authority said Tuesday.
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February 17, 2026
Sweden Proposes New Tools To Combat VAT Fraud
Swedish lawmakers are mulling legislation that would target value-added tax fraud through a series of new measures, including enabling tax officials to deny VAT registration if they see red flags, Sweden's Finance Ministry announced Tuesday.
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February 17, 2026
EU Blacklists Turks and Caicos, Vietnam As Tax Havens
The European Union blacklisted two countries as tax havens Tuesday over their failure to meet transparency standards and policies encouraging foreign companies and entities to shift their profits overseas.
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February 13, 2026
Senate Dems Say IRS-ICE Privacy Warnings Proved Correct
The Internal Revenue Service's recent admission that a faulty system improperly shared taxpayer records with U.S. Immigration and Customs Enforcement vindicates long-standing warnings about privacy and data protection risks, Senate Democrats said.
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February 13, 2026
Gov'ts To Explore Transfer Pricing Database For UN Tax Pact
Governments are expected to form a task force on improving access to transfer pricing information, including by potentially creating a database, to support the dispute protocol under the United Nations framework convention on international tax cooperation, according to negotiations on the protocol held Friday.
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February 13, 2026
FinCEN Eases Beneficial Owner ID Rules For Banks
The U.S. Treasury Department's Financial Crimes Enforcement Network announced Friday that banks are excepted from certain aspects of the agency's customer due diligence rules, including the requirement to repeatedly identify the beneficial owners of existing corporate account holders.
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February 13, 2026
Taxation With Representation: Homburger, Lenz & Staehelin
In this week's Taxation With Representation, offshore drilling contractor Transocean Ltd. acquires rival Valaris Ltd., historic British fund manager Schroders agrees to a cash takeover by U.S. asset manager Nuveen, and a consortium that includes U.S. private equity firm Advent International LP and FedEx Corp. buy Polish parcel locker company InPost.
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February 13, 2026
Blair's Think Tank Urges UK Gov't To End Energy Windfall Tax
The U.K.'s Labour government must phase out the windfall tax on the energy industry and lift the ban on new oil and gas drilling licenses in the North Sea to increase revenue long term, the Tony Blair Institute said Friday.
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February 12, 2026
Gov'ts Favor Optionality In UN Tax Treaty's Dispute Protocol
Governments widely supported having the ability to choose between options for dispute resolution and prevention while making an opt-out unavailable for some methods in the dispute protocol under the United Nations framework convention on international tax cooperation, according to negotiations on the protocol.
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February 12, 2026
Canadian Living In Wash. Says FBAR Penalty Required Jury
A Canadian man living in the U.S. was unconstitutionally fined more than $700,000 for failing to report his foreign bank accounts, he told a Washington federal court, arguing that the amount is excessive and that its assessment violates his right to a jury trial.
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February 12, 2026
Hotel Cos. Urge UK Gov't To Abandon Holiday Tax Proposal
The Labour government should not introduce what is known as a holiday tax on the hospitality industry, more than 200 hotel companies told the U.K.'s finance minister.
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February 12, 2026
Dinsmore Adds IRS Senior Counsel As Tax Partner In DC
An attorney who spent more than a decade working as an attorney and reviewer at the Internal Revenue Service has joined Dinsmore & Shohl LLP's Washington, D.C., tax group, the firm announced this week.
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February 12, 2026
Broker Says Denmark Can't Bring £56M Cum-Ex Fraud Claim
An English broker told Britain's top court on Thursday that Denmark's tax authority can't sue it for more than £56 million ($76 million) over a tax refund fraud, because an earlier decision in related proceedings rendered the claim inadmissible.
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February 11, 2026
House OKs Ending Canada Tariffs After GOP Block Fails
The U.S. House of Representatives approved a resolution Wednesday evening that would end President Donald Trump's tariffs on Canadian imports, a day after Republican lawmakers were unable to pass a measure blocking that kind of effort.
UK Court Blocks Telecom's £51M VAT Refund Bid
A London appeals court dismissed a U.K. telecommunications provider's bid to recover £51.1 million ($69.3 million) in value-added tax payments, agreeing with a lower court's conclusion that VAT is owed when phone plans are sold, not when they're used.
Fuel Credit Regs Clear Clouds Over Middleman Sales
The U.S. Treasury Department's move to allow domestic clean fuel producers selling to intermediaries to qualify for the production tax credit under newly released proposed rules recognizes the industry's commercial realities and clears up uncertainty that had been hindering the market, practitioners said.
IRS Guidance Offers Relief In Energy Credits' Sourcing Limits
The IRS issued interim guidance Thursday providing two safe harbor options for clean energy facilities or manufacturers of energy components to determine the extent to which they received material assistance from an entity tied to a foreign government that the U.S. deems adversarial.
UK Court Blocks Telecom's £51M VAT Refund Bid
A London appeals court dismissed a U.K. telecommunications provider's bid to recover £51.1 million ($69.3 million) in value-added tax payments, agreeing with a lower court's conclusion that VAT is owed when phone plans are sold, not when they're used.
Fuel Credit Regs Clear Clouds Over Middleman Sales
The U.S. Treasury Department's move to allow domestic clean fuel producers selling to intermediaries to qualify for the production tax credit under newly released proposed rules recognizes the industry's commercial realities and clears up uncertainty that had been hindering the market, practitioners said.
IRS Guidance Offers Relief In Energy Credits' Sourcing Limits
The IRS issued interim guidance Thursday providing two safe harbor options for clean energy facilities or manufacturers of energy components to determine the extent to which they received material assistance from an entity tied to a foreign government that the U.S. deems adversarial.
Featured Stories
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Fuel Credit Regs Clear Clouds Over Middleman Sales
The U.S. Treasury Department's move to allow domestic clean fuel producers selling to intermediaries to qualify for the production tax credit under newly released proposed rules recognizes the industry's commercial realities and clears up uncertainty that had been hindering the market, practitioners said.
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3 Things To Keep In Mind About IRS' Corporate Audit Changes
The IRS' revamped audit process for corporate taxpayers will likely streamline examinations, but companies may now shoulder new responsibilities when presenting facts and face lingering uncertainties when weighing whether to participate in a broadened settlement program. Here, Law360 examines three key issues for companies to consider under the new audit process.
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Congress' Limited Tariff Role May Persist After Justices Rule
The U.S. Supreme Court's ruling on President Donald Trump's emergency tariffs could leave the door open for Congress to play a larger role in trade policy heading into November's midterms, but that opportunity may pose few political incentives for lawmakers.
Expert Analysis
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Judges On AI: Practical Use Cases In Chambers
U.S. Magistrate Judge Allison Goddard in the Southern District of California discusses how she uses generative artificial intelligence tools in chambers to make work more efficient and effective — from editing jury instructions for clarity to summarizing key documents.
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Malpractice Claim Assignability Continues To Divide Courts
Recent decisions from courts across the country demonstrate how different jurisdictions balance competing policy interests in determining whether legal malpractice claims can be assigned, providing a framework to identify when and how to challenge any attempted assignment, says Christopher Blazejewski at Sherin & Lodgen.
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NYC Bar Opinion Warns Attys On Use Of AI Recording Tools
Attorneys who use artificial intelligence tools to record, transcribe and summarize conversations with clients should heed the New York City Bar Association’s recent opinion addressing the legal and ethical risks posed by such tools, and follow several best practices to avoid violating the Rules of Professional Conduct, say attorneys at Smith Gambrell.
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4 Quick Emotional Resets For Lawyers With Conflict Fatigue
Though the emotional wear and tear of legal work can trap attorneys in conflict fatigue — leaving them unable to shake off tense interactions or return to a calm baseline — simple therapeutic techniques for resetting the nervous system can help break the cycle, says Chantel Cohen at CWC Coaching & Therapy.
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Judges On AI: How Judicial Use Informs Guardrails
U.S. Magistrate Judge Maritza Dominguez Braswell at the U.S. District Court for the District of Colorado discusses why having a sense of how generative AI tools behave, where they add value, where they introduce risk and how they are reshaping the practice of law is key for today's judges.
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Key False Claims Act Trends From The Last Year
The False Claims Act remains a powerful enforcement tool after some record verdicts and settlements in 2025, and while traditional fraud areas remain a priority, new initiatives are raising questions about its expanding application, says Veronica Nannis at Joseph Greenwald.
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Hosting Exchange Students Makes Me A Better Lawyer
Opening my home to foreign exchange students makes me a better lawyer not just because prioritizing visiting high schoolers forces me to hone my organization and time management skills but also because sharing the study-abroad experience with newcomers and locals reconnects me to my community, says Alison Lippa at Nicolaides Fink.
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How A 1947 Tugboat Ruling May Shape Work Product In AI Era
Rapid advances in generative artificial intelligence test work-product principles first articulated in the U.S. Supreme Court’s nearly 80-year-old Hickman v. Taylor decision, as courts and ethics bodies confront whether disclosure of attorneys’ AI prompts and outputs would reveal their thought processes, say Larry Silver and Sasha Burton at Langsam Stevens.
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Navigating Privilege Law Patchwork In Dual-Purpose Comms
Three years after the U.S. Supreme Court declined to resolve a circuit split in In re: Grand Jury, federal courts remain split as to when attorney-client privilege applies to dual-purpose legal and business communications, and understanding the fragmented landscape is essential for managing risks, say attorneys at Covington.
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4 Ways GCs Can Manage Growing Service Of Process Volume
As automation and arbitration increase the volume of legal filings, in-house counsel must build scalable service of process systems that strengthen corporate governance and manage risk in real time, says Paul Mathews at Corporation Service Co.
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The Law Firm Merger Diaries: Forming Measurable Ties
Relationship-building should begin as early as possible in a law firm merger, as intentional pathways to bringing people together drive collaboration, positive client response, engagements and growth, says Amie Colby at Troutman.
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OFAC Sanctions Will Intensify Amid Global Tensions In 2026
The Office of Foreign Assets Control will ramp up its targeting of companies in the private equity, venture capital, real estate and legal markets in 2026, in keeping with the aggressive foreign policy approach embraced by the Trump administration in 2025, say attorneys at Holland & Knight.
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5 E-Discovery Predictions For 2026 And Beyond
2026 will likely be shaped by issues ranging from artificial intelligence regulatory turbulence to potential evidence rule changes, and e-discovery professionals will need to understand how to effectively guide the responsible and defensible adoption of emerging tools, while also ensuring effective safeguards, say attorneys at Littler.