International

  • February 08, 2026

    HMRC Nets £246M In Evasion-Focused Inheritance Tax Probes

    Britain's tax authority has recovered an additional £246 million ($336 million) in inheritance tax secured by investigations, according to data released Sunday.

  • February 06, 2026

    4 Takeaways From The EU's Latest Trade Agreements

    The European Union recently cemented formal trade agreements with India and Mercosur, a group of Latin American countries, which — along with creating certainty for businesses in the regions — strike a sharp contrast with the approach taken in framework deals reached by President Donald Trump. Here, Law360 examines four takeaways from the two trade agreements announced by the EU.

  • February 06, 2026

    Trump Orders 25% Tariff For Countries With Biz Ties To Iran

    President Donald Trump signed an executive order Friday afternoon that threatens a 25% tariff on the imports entering the U.S. of countries found to be purchasing goods or services from Iran.

  • February 06, 2026

    Partnership Asks Justices To Restore $23M Loss Deduction

    A partnership asked the U.S. Supreme Court to revive its $23 million loss deduction involving a Brazilian company, saying in a petition docketed Friday that the Second Circuit wrongly blocked a key argument and that an IRS anti-abuse regulation applied against the partnership should be invalidated.

  • February 06, 2026

    Gov'ts Want Safeguards For Tax Data Swaps In UN Pact

    The United Nations' framework convention on international tax cooperation must ensure that exchanges of taxpayer information take place only when the information is foreseeably relevant to the requesting government's enforcement of tax laws, several representatives said Friday during negotiations.

  • February 06, 2026

    Buchanan Ingersoll Adds 2 Veteran Tax Pros In DC

    Buchanan Ingersoll & Rooney PC has expanded its tax offerings in the nation's capital with two attorneys, including the former co-chair of the tax and private wealth practice at Whiteford Taylor & Preston LLP.

  • February 06, 2026

    Gunster Brings On Longtime Tax Law Professor In Florida

    Florida business law firm Gunster has added an experienced tax law professor to its ranks as of counsel.

  • February 06, 2026

    Taxation With Representation: Gibson Dunn, S&C, Wachtell

    In this week's Taxation With Representation, Elon Musk announces SpaceX's acquisition of his artificial intelligence company xAI, Devon Energy and Coterra Energy agree to merge, and Banco Santander SA acquires Webster Financial Corp.

  • February 06, 2026

    CPAs Suggest Treasury Scrap Doc Plans For CFC Rules

    The U.S. Treasury Department should rethink planned documentation requirements for overseas income allocations, the American Institute of Certified Public Accountants recommended in a letter released Friday, saying the rules may be unnecessarily burdensome.

  • February 05, 2026

    Russian Scientist's US Wages Not Tax-Exempt, Tax Court Says

    The U.S. Department of Energy's payments to a Russian scientist for subatomic particle research in Virginia don't fall under a U.S.-Russia tax treaty covering tax-exempt grants, the U.S. Tax Court held Thursday.

  • February 05, 2026

    UN Talks Aim To Identify Gaps On Harmful Tax Practices

    Representatives of governments asked their colleagues Thursday to pinpoint gaps in ongoing efforts to address harmful tax practices in order to sharpen the United Nations' framework convention on international tax cooperation.

  • February 05, 2026

    Ga. Law Firm's CTA Challenge 'Hypothetical,' Feds Argue

    The U.S. Treasury Department has asked a federal judge to toss a Georgia lawyer's suit alleging that the 2021 Corporate Transparency Act could force him to violate attorney-client privilege, arguing the suit is based on future "hypothetical changes" to the federal policy of nonenforcement.

  • February 05, 2026

    Hostages Aren't Receiving Tax Relief, TIGTA Says

    Recently released hostages did not receive tax relief despite the Internal Revenue Service implementing new procedures to improve the process to provide tax relief to taxpayers wrongfully detained or taken hostage, the Treasury Inspector General for Tax Administration said in a report released Thursday.

  • February 04, 2026

    Developing Nations See Tax Data Swaps Lacking Reciprocity

    Developing countries' requests for taxpayer information are often denied by other countries even as the resource-strapped nations have invested resources in fulfilling incoming requests, government officials said Wednesday.

  • February 04, 2026

    Tax Group Of The Year: Davis Polk

    Davis Polk & Wardwell LLP scored a significant victory for Exxon Mobil in litigation concerning the tax treatment of a major partnership with Qatar and oversaw several other complex, high-stakes transactions, earning it recognition as a 2025 Law360 Tax Practice Group of the Year.

  • February 04, 2026

    IRS Urges Tax Court To Cut $315M From Siemens Deduction

    The Internal Revenue Service defended its slashing of $315 million from a tax deduction that medical giant Siemens claimed on payments from overseas, telling the U.S. Tax Court that rule writers had congressional backing to issue the regulations underpinning the adjustment.

  • February 04, 2026

    Walmart Wants Relief In CFC Tax Year Deferral

    Walmart asked the U.S. Department of the Treasury to temporarily allow certain taxpayers to file a single 13-month return, instead of two separate returns, in the wake of filing changes regarding controlled foreign corporations, according to a letter released Wednesday.

  • February 04, 2026

    One Essex Court Barrister Sued For Negligence In £32M Case

    Billionaire Michael Platt and his hedge fund have accused a One Essex Court barrister of negligence by failing to set out two key appeal arguments in a dispute with tax authorities over a £32.25 million ($44 million) charge.

  • February 03, 2026

    Dairy Co. Presses UK Court To Revive Tax Deductions On IP

    A European dairy giant asked a London appeals court on Tuesday to overturn lower tribunal rulings denying the company tax deductions for the gradual write-off of brands, intellectual property and goodwill following an acquisition.

  • February 03, 2026

    Gov'ts Resist Binding Treaty Renegotiations In UN Tax Pact

    Several governments expressed opposition Tuesday to a proposed requirement for countries to renegotiate bilateral tax treaties in line with principles aimed at fairly allocating taxing rights as part of the United Nations framework convention on international tax cooperation.

  • February 03, 2026

    IRS Floats Clean Fuel Credit Rules With Foreign Restrictions

    The Internal Revenue Service released long-awaited proposed regulations Tuesday clarifying how domestic transportation fuel producers can qualify for the clean energy fuel tax credit under changes made by Republicans' 2025 budget law, including new foreign restrictions on business owners and feedstock sources.

  • February 03, 2026

    French Gov't Approves Budget With New Corp. Tax Measures

    The French government has adopted a budget that targets wealthy people and corporations, including a surtax on the country's biggest companies that is expected to bring in €7.3 billion ($8.6 billion).

  • February 03, 2026

    Virgin Islands Co. Wants Experts Barred In $11.5M Pricing Row

    A U.S. Virgin Islands mortgage company challenging the territorial government over $11.5 million in tax bills asked a federal court Tuesday to exclude expert testimony meant to bolster the government's case that the company wrongly claimed a tax break meant to help the local economy.

  • February 03, 2026

    HMRC Disputes Danish Wind Farm's Tax Relief At Top Court

    Britain's tax authority told the U.K. Supreme Court on Tuesday that a Danish wind farm company can't claim tax relief on pre-development costs for building wind farms, because the costs are too remote from the actual provision of plants and machinery.

  • February 02, 2026

    Int'l Tax In January: Global Min. Reached, Trade Deals Abound

    January was a busy month in international tax, starting with an agreement by nearly 150 countries on a global minimum tax that effectively exempts U.S. companies and culminating with trade deals between Canada and China as well as India and the European Union. Here, Law360 looks at the biggest developments in international tax over the last month.

Expert Analysis

  • Rules Of Origin Revamp May Be Next Big Trade Development

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    The rules of origin for determining what tariff applies to any given import appear to be on the cusp of an important rethink, and it seems likely that the administration will try to align the rule with its overall tariff strategy in one of three ways, says Ted Posner at Baker Botts.

  • SDNY OpenAI Order Clarifies Preservation Standards For AI

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    The Southern District of New York’s recent order in the OpenAI copyright infringement litigation, denying discovery of The New York Times' artificial intelligence technology use, clarifies that traditional preservation benchmarks apply to AI content, relieving organizations from using a “keep everything” approach, says Philip Favro at Favro Law.

  • High Court, Not A Single Justice, Should Decide On Recusal

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    As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.

  • Adapting To Private Practice: 3 Tips On Finding The Right Job

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    After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.

  • Painting Makes Me A Better Lawyer

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    Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.

  • Protecting Sensitive Court Filings After Recent Cyber Breach

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    In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.

  • What Ethics Rules Say On Atty Discipline For Online Speech

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    Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.

  • 2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers

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    Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.

  • Junior Attys Must Beware Of 5 Common Legal Brief Mistakes

    Excerpt from Practical Guidance
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    Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.

  • Power To The Paralegals: How And Why Training Must Evolve

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    Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.

  • 5 Real Estate Takeaways From Trump's Sweeping Tax Law

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    Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.

  • Evaluating The Current State Of Trump's Tariff Deals

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    As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.

  • How Hyperlinks Are Changing E-Discovery Responsibilities

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    A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.

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