International

  • December 12, 2025

    Treasury Issues Final Rules For Taxing Foreign Gov't Income

    The U.S. Treasury Department issued final regulations Friday for determining whether income of foreign governments derived within the U.S. is taxable along with proposed regulations concerning when a foreign government has effective control of a commercial entity.

  • December 12, 2025

    Taxation With Representation: Cravath, Skadden, Debevoise

    In this week's Taxation With Representation, Paramount Skydance Corp. launches a hostile bid for Warner Bros. Discovery, challenging Netflix's deal to acquire the studio and streaming business, IBM acquires data streaming company Confluent, and natural gas company Antero Resources Corp. expands via a deal with HG Energy.

  • December 11, 2025

    Judge Slams Eaton Expert For Offering Legal Analysis

    A report submitted by one of Eaton's expert witnesses in its acquisition financing trial overstepped the limits of an expert's role, offering legal rather than economic analysis and seeming to advocate for the company​​​​, a U.S. Tax Court judge said Thursday.

  • December 11, 2025

    Fed Terminates 3 Actions Against Credit Suisse, JPMorgan

    The Federal Reserve said Thursday that it has terminated a trio of enforcement actions against Credit Suisse Group AG and JPMorgan Chase & Co., lifting consent orders that were tied to alleged illicit finance practices and trade surveillance failures.

  • December 11, 2025

    Wealth Taxes Can Succeed Despite Flaws, EU Panel Hears

    Wealth taxes have underperformed across the European Union because of design flaws, but this doesn't mean such levies can't work or that there are no alternatives, tax experts said Thursday.

  • December 11, 2025

    EU Corporate Tax Compliance Shortfall About €38B, Bloc Says

    Countries in the European Union didn't collect about €38 billion ($44.7 billion) in corporate income tax liabilities due to noncompliance in 2017 and about €128 billion of value-added tax liabilities in 2023, the bloc's executive branch said Thursday in a series of reports.

  • December 10, 2025

    Judge Probes IRS Expert On Method For Eaton's Credit Rating

    A U.S. Tax Court judge asked an IRS expert Wednesday about his calculation of a standalone credit rating for Eaton's U.S. group in 2012, when it acquired an Irish entity and inverted, noting that the expert, unlike ratings agency Standard & Poor's, factored in Eaton's debt to the Irish parent.

  • December 10, 2025

    Estonia Blocks OECD Adopting US' Global Min. Tax Exemption

    Estonia formally opposed the U.S. government's proposed exemption for American companies from the 15% global minimum tax's international provisions during an adoption procedure held by the OECD, the country's Ministry of Finance said Wednesday, blocking the adoption for now.

  • December 10, 2025

    Australia Issues Guidance On Tax Transparency Exemptions

    Australia will consider granting exemptions to public country-by-country reporting of tax information to companies that can demonstrate their compliance would reveal commercially sensitive information, violate Australian or foreign laws or negatively impact national security, according to final guidance issued by the Australian Taxation Office.

  • December 10, 2025

    Reeves Denies Gov't Authorized UK Budget Leak

    British Chancellor of the Exchequer Rachel Reeves told a parliamentary committee Wednesday that she didn't authorize briefings of policy discussions to the media ahead of the autumn budget statement.

  • December 10, 2025

    Frankfurt Police Seize Assets In VAT Fraud Crackdown

    Authorities in Frankfurt, Germany, searched two properties, seizing cash and documents, in a suspected case of value-added tax fraud, according to a statement Wednesday.

  • December 09, 2025

    Judge Wants Cost-Benefit Analysis Of Eaton Guarantees

    A U.S. Tax Court judge asked one of Eaton's experts Tuesday how much the company could have saved by issuing debt from its new Irish parent in 2012 instead of having the parent guarantee bonds the U.S. company issued to third parties.

  • December 09, 2025

    Tariffs Add Complexity To State Tax Systems, Tax Pros Say

    Tariffs promoted by President Donald Trump's administration are increasing state sales and use tax complexity and risk, which may not easily be undone even if the U.S. Supreme Court strikes the tariffs down, tax professionals said Tuesday.

  • December 09, 2025

    OECD's Average Tax-To-GDP Hits Record 34.1%, Report Says

    The OECD's average ratio of tax to gross domestic product reached a record 34.1% last year, the organization said Tuesday, marking the first annual increase since 2021.

  • December 09, 2025

    Sabre Tax Dispute Belongs In UK Court, British Airways Says

    Flight booking giant Sabre's lawsuit over a U.K. digital tax bill should be dismissed or left for a British court to rule on, British Airways told a Texas federal court, arguing that the digital services tax is a matter for U.K. law.

  • December 08, 2025

    Conservative Justices Probe 'Husk' Of FTC Firing Protections

    The U.S. Supreme Court's conservative majority pushed back Monday against the 90-year-old precedent permitting the removal only for cause of Federal Trade Commission members, and perhaps those serving other independent agencies, calling those safeguards a "dried husk" and wondering where to draw the line for protected agencies.

  • December 08, 2025

    Meta Fights $16B Tax Bill Over Facebook's Cost-Sharing Deal

    Facebook parent Meta Inc. is challenging a nearly $16 billion tax bill stemming from an agreement with an Irish affiliate to share the costs of developing intangibles, telling the U.S. Tax Court that the IRS can't relitigate issues the court already addressed.

  • December 08, 2025

    11th Circ. Affirms Tax Court Wrong Venue For FBAR Challenge

    The U.S. Tax Court isn't the right venue for a couple to challenge the Internal Revenue Service's denial of a hearing over the agency withholding their Social Security benefits to cover penalties stemming from their failure to report foreign bank accounts, the Eleventh Circuit affirmed Monday.

  • December 08, 2025

    Hogan Lovells Adds Latham Corporate Ace In Houston

    Hogan Lovells announced Monday that it has bolstered its tax, pensions and benefits offerings with a Houston-based attorney who came aboard from Latham & Watkins LLP.

  • December 05, 2025

    Eaton's Position On Parental Support Conflicting, Judge Says

    Eaton is telling "different stories at different times" about the ability of its foreign parent company to step in and pay the U.S. company's debt obligations to third parties, Tax Court Judge Albert Lauber said in questioning one of the company's experts Friday.

  • December 05, 2025

    Swiss To Charge VAT To Platforms For Software, Streaming

    Switzerland is planning to collect value-added taxes from platforms for selling electronic services like software, streaming and digital content, rather than from individual sellers, extending a system already in place for mail-order e-commerce companies, the country's finance department said Friday.

  • December 05, 2025

    IRS-ICE Data Swap Halt Irrelevant In Other Suit, DC Circ. Told

    A D.C. federal court's order pausing the Internal Revenue Service's ability to share confidential taxpayer addresses with immigration enforcement officials should not impact a separate D.C. Circuit proceeding over whether the information-sharing agreement complies with taxpayer privacy protections, the U.S. government told the D.C. Circuit.

  • December 05, 2025

    Huntsman Disputes $28.6M Tax Bill From Cut Capital Loss

    Multinational chemical manufacturer Huntsman is challenging the IRS over a $28.6 million tax bill that resulted from the agency reducing its carried-forward loss from selling a spun-off pigments business, according to a petition filed in the U.S. Tax Court.

  • December 05, 2025

    Asian Tax Systems Seen As More Fair, OECD Report Says

    Taxpayers in Asian countries are more likely to perceive their tax systems as equitable compared to individuals in other regions, according to a report from the Organization for Economic Cooperation and Development and international accounting groups.

  • December 04, 2025

    Judge Skeptical Implicit Support Worthless To Eaton Investors

    A U.S. Tax Court judge closely questioned Thursday an expert for Eaton who said potential investors would not have counted on financial support from the company's parent in the event it couldn't meet its obligations after acquiring an Irish entity and inverting in 2012.

Expert Analysis

  • Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example

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    Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.

  • Accountant-Owned Law Firms Could Blur Ethical Lines

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    KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.

  • AI Will Soon Transform The E-Discovery Industrial Complex

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    Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.

  • Unpacking The Legal Foundation Of Trump's New Trade War

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    President Donald Trump's recent executive orders and proclamations regarding emergencies at the U.S. border are based on statutory powers enabling a president to address extraordinary external threats — and could be used to fend off legal challenges to the tariffs levied on Mexican and Canadian goods, says Chris Zona at Mandelbaum Barrett.

  • When Innovation Overwhelms The Rule Of Law

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    In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.

  • Imagine The Possibilities Of Openly Autistic Lawyering

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    Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.

  • Litigation Funding Disclosure Debate: Strategy Considerations

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    In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.

  • 5 Ways To Create Effective Mock Assignments For Associates

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    In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.

  • Mentorship Resolutions For The New Year

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    Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.

  • Tax Directive Marks Milestone In Harmonizing EU System

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    The Council of the European Union’s recently adopted tax directive is a significant step toward streamlining and modernizing procedures for member states, and will greatly reduce administrative burden and compliance costs for cross-border investors, says Martin Phelan at Simmons & Simmons.

  • 5 Litigation Funding Trends To Note In 2025

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    Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.

  • Rethinking Litigation Risk And What It Really Means To Win

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    Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.

  • Small Biz Caught In Corporate Transparency Act Crossfire

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    Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.

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