International

  • 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."

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • February 17, 2026

    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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • February 13, 2026

    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.

  • 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.

  • 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.

  • February 12, 2026

    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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • Power To The Paralegals: The Value Of Unified State Licensing

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    Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.

  • 10 Soft Skills Every GC Should Master

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    As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.

  • 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.

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