International

  • March 13, 2026

    Taxation With Representation: Paul Hastings, Duane Morris

    In this week's Taxation With Representation, uniform maker Cintas Corp. acquires workwear company UniFirst Corp., Controlled Thermal Resources Holdings Inc. plans to go public by merging with a special purpose acquisition company, and a Shell USA Inc. subsidiary sells Jiffy Lube International Inc. to Monomoy Capital Partners.

  • March 13, 2026

    OECD Business Group Calls For Further Pillar 2 Planning

    The OECD's business stakeholder group on Friday called for "continued refinement" of Pillar Two readiness plans to ensure a smooth application of the 15% global minimum tax on corporate profits. 

  • March 12, 2026

    Tariff Refund System Taking Shape, US Customs Tells CIT

    U.S. Customs and Border Protection is making progress developing a system for importers to claim refunds for the global tariff regime struck down by the U.S. Supreme Court, an official told the U.S. Court of International Trade on Thursday.

  • March 12, 2026

    Microsoft, Michigan Settle Cost-Share Receipts Tax Fight

    Microsoft and Michigan reached a settlement over the company's challenge to the state's tax treatment of its cost-sharing agreement receipts with foreign affiliates, according to a dismissal order entered Thursday by the state's Tax Tribunal.

  • March 12, 2026

    IRS Allows 15% Of KFC Parent's Domestic Production Claim

    The IRS and the parent of Pizza Hut, KFC and Taco Bell agreed that the company's total deductions for domestic production activities during 2013-2015 were $1.6 million — roughly 15% of the $10.7 million the company had claimed as deductions for the three years.

  • March 12, 2026

    Reeves Says Energy Windfall Tax May Not Apply By Late 2027

    The U.K.'s energy profits levy is expected to no longer apply to oil and gas operations in the North Sea in the last quarter of 2027, especially if the current Middle East crisis de-escalates and energy prices stabilize, Chancellor of the Exchequer Rachel Reeves told an H&M Treasury committee.

  • March 12, 2026

    Alleged IRS Errors Don't Merit Injunction, Judge Advises

    A Puerto Rico magistrate judge recommended denying a taxpayer's bid to block the IRS from assessing her tax liabilities while the agency's clerical errors that she alleges remain unresolved, holding that she faces uncertainties that don't rise to the level of irreparable harm.

  • March 12, 2026

    EU Top Court Allows Spain's Entertainment VAT Break Limit

    Spain's restriction on VAT deductions linked to entertainment expenses doesn't constitute a violation of European Union law, the bloc's top court said Thursday, rejecting a human resources firm's claim that the country was illegally blocking refunds on business costs.

  • March 11, 2026

    Costco Owes Shoppers Refunds For Voided Tariffs, Suit Says

    Costco shoppers are owed back the higher costs they paid as a result of President Donald Trump's global tariffs that the nation's highest court has since declared unlawful, according to a putative consumer class action filed Wednesday in Illinois federal court.

  • March 11, 2026

    Varian Case Backs $315M Siemens Deduction, Tax Court Told

    The U.S. Tax Court should restore $315 million of Siemens' foreign-dividend tax deduction for the same reasons it upheld a similar deduction for Varian Medical Solutions in 2024, an attorney for Siemens told the court Wednesday.

  • March 11, 2026

    Cos. Ask Court To Toss Trump's Revamped Global Tariffs

    Two companies are challenging President Donald Trump's revamped global tariff regime, telling the U.S. Court of International Trade that the circumstances required to justify the regime cannot exist.

  • March 11, 2026

    Dairy Giant Loses Bid For UK Tax Deductions On IP Transfers

    A London court on Wednesday dismissed a European dairy giant's appeal seeking corporate tax deductions for intellectual property transferred to the partnership by its corporate members.

  • March 11, 2026

    EU Refers Spain To Top Court For Inaction On VAT Directives

    Spain will be referred to the European Union's top court for failing to incorporate two legal directives on value-added tax into Spanish law by a December 2024 deadline, the EU's executive arm said Wednesday.

  • March 11, 2026

    Transfer Pricing Cases Collected £3.4B Last Year, HMRC Says

    The U.K. brought in £3.4 billion ($4.6 billion) in additional revenue from transfer pricing cases from 2024-2025, nearly double the amount from the previous year, according to HM Revenue & Customs data released Wednesday.

  • March 11, 2026

    Barrister's Libel Claim Against Neidle Dismissed As SLAPP

    A judge has struck out a barrister's £8 million ($11 million) libel claim against Dan Neidle, ruling on Wednesday that the case had no chance of succeeding and amounted to a strategic legal claim designed to silence the legal blogger. 

  • March 10, 2026

    Hewlett Packard To Fight IRS Transfer Pricing Adjustments

    Hewlett Packard Enterprise Co. disagrees with transfer pricing adjustments by the IRS and will challenge the agency's efforts to increase its taxable income, the company said in a quarterly report released Tuesday.

  • March 10, 2026

    Exxon Wins $27M Deduction In Canadian Tax Dispute

    The Tax Court of Canada backed Exxon Mobil's bid for a CA$36.2 million ($26.7 million) income deduction for expenses tied to an abandoned Alaskan pipeline project, holding that the company incurred the costs while conducting legitimate business operations.

  • March 10, 2026

    PE Group Asks 3rd Circ. To Overturn Fund's $100M Tax Bill

    The U.S. economy could face damaging consequences if the Third Circuit upholds a U.S. Tax Court decision finding a Cayman Islands hedge fund liable for a $100 million tax bill as a securities dealer, a private equity lobbying group told the court.

  • March 10, 2026

    French Tax Take Outpaces Economic Growth

    France's net tax revenue reached €610 billion ($710 billion) in fiscal year 2025, growing three times faster than GDP, the French tax authority said Tuesday.

  • March 10, 2026

    Portugal Warns Of Carbon Tax Abuse If Exemptions Granted

    A more lenient application of the European Union's carbon leakage tax in the bloc's outermost regions would risk tax evasion, Portugal's finance minister said during a meeting to discuss the bloc's economic agenda.

  • March 10, 2026

    Medtronic, IRS Pursuing Settlement In Transfer Pricing Case

    Medtronic and the Internal Revenue Service are exploring the possibility of settling their U.S. Tax Court case, the parties said, which would avoid the need for a third trial on the pricing intangibles that the Minnesota-based company licensed to its Puerto Rican affiliate in 2005 and 2006.

  • March 10, 2026

    Alston & Bird Adds Deals Pro From Proskauer To Tax Team

    Alston & Bird LLP announced on Tuesday that it has welcomed a tax attorney from Proskauer Rose LLP, saying that his hire will benefit its transactional team and its private equity clients.

  • March 09, 2026

    2nd Circ. Says COVID Policy Saves Argentine Creditors' Case

    The Second Circuit on Monday revived a $5.5 million contractual dispute against Argentina, ruling that a New York state COVID-19 policy saved some bondholder claims from being time-barred.

  • March 09, 2026

    Mining Co. Weighs Arbitration With Mozambique Tax Authority

    An Irish mining company said Monday it's considering international arbitration for a dispute with the Mozambique Tax Authority over the agency's imposition of higher royalties during negotiations on renewing an investment agreement.

  • March 09, 2026

    Omni Bridgeway Gets Green Light To Target Albania Assets

    A Washington, D.C., federal judge agreed to let litigation funder Omni Bridgeway seize assets belonging to the Albanian government as it looks to enforce an arbitral award now worth some $13 million that the country has ignored for years.

Expert Analysis

  • Judges On AI: How Courts Can Boost Access To Justice

    Author Photo

    Arizona Court of Appeals Judge Samuel A. Thumma writes that generative artificial intelligence tools offer a profound opportunity to enhance access to justice and engender public confidence in courts’ use of technology, and judges can seize this opportunity in five key ways.

  • The Case For Emulating, Not Dividing, The Ninth Circuit

    Author Photo

    Champions for improved judicial administration should reject the unfounded criticisms driving recent Senate proposals to divide the Ninth Circuit and instead seek to replicate the court's unique strengths and successes, says Ninth Circuit Judge J. Clifford Wallace.

  • 5 Tariff And Trade Developments To Watch In 2026

    Author Photo

    A new trade landscape emerged in 2025, the contours of which will be further defined by developments that will merit close attention this year, including a key ruling from the U.S. Supreme Court and a review of the U.S.-Mexico-Canada Agreement, says Ted Posner at Baker Botts.

  • 4 Developments That Defined The 2025 Ethics Landscape

    Author Photo

    The legal profession spent 2025 at the edge of its ethical comfort zone as courts, firms and regulators confronted how fast-moving technologies and new business models collide with long-standing professional duties, signaling that the profession is entering a period of sustained disruption that will continue into 2026, says Hilary Gerzhoy at HWG Law.

  • How Fractional GCs Can Manage Risks Of Engagement

    Author Photo

    As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.

  • How OECD Tax Update Tackles Mobile Workforce Complexity

    Author Photo

    The Organization for Economic Cooperation and Development’s recently updated model tax convention — a recalibration of international tax principles in response to an increasingly mobile workforce — should prompt companies to reevaluate cross-border operations, transfer pricing policies and tax controversy strategies, say attorneys at Eversheds.

  • A Uniform Federal Rule Would Curb Gen AI Missteps In Court

    Author Photo

    To address the patchwork of courts’ standing orders on generative artificial intelligence, curbing abuses and relieving the burden on judges, the federal judiciary should consider amending its civil procedure rules to require litigants to certify they’ve reviewed legal filings for accuracy, say attorneys at Shook Hardy.

  • Supreme Court Term Limits Would Carry Hidden Risk

    Author Photo

    While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.

  • Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave

    Author Photo

    The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.

  • AI Evidence Rule Tweaks Encourage Judicial Guardrails

    Author Photo

    Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.

  • The Law Firm Merger Diaries: Getting The Message Across

    Author Photo

    Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.

  • Horizontal Stare Decisis Should Not Be Casually Discarded

    Author Photo

    Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.

  • 10 Commandments For Agentic AI Tools In The Legal Industry

    Author Photo

    Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.