International

  • April 07, 2026

    Partnership Wants Tax Court To Reconsider Basis Question

    A partnership asked the U.S. Tax Court to reconsider its finding that a company contributing a promissory note for a stake in the partnership had zero basis in the note, saying basis must be determined when a note is contributed, not at its conception.

  • April 07, 2026

    UK Oil Co. Can Avoid £167M Tax Assessment, Tribunal Says

    A U.K. oil company isn't liable for a £167 million ($221 million) increase to its taxable profits because for tax purposes it shouldn't be treated as having acquired an oil-related business following an intra-group transfer, according to an Upper Tribunal decision published Tuesday.

  • April 07, 2026

    IRS Updates Foreign Housing Expense Limits For 2026

    The Internal Revenue Service released adjustments Tuesday to the limitation on foreign housing expense deductions and exclusions for 2026.

  • April 07, 2026

    HMRC Clarifies Tax Relief For Investors Moving To UK

    Individuals who moved to the U.K. in recent years have until the end of January 2028 to file for tax relief under the foreign income and capital gains regime, Britain's tax authority said in new guidance Tuesday.

  • April 07, 2026

    Floridian Says Jury Was Required Before $20M FBAR Fine

    A dual U.S.-German citizen urged a Florida federal court to reject a magistrate judge's recommendation to uphold a nearly $20 million tax judgment for undisclosed foreign bank account information, contending the judge failed to recognize a recent change in the law about access to jury trials. 

  • April 08, 2026

    CORRECTED: HMRC Takes On New Powers As Tax Dodge Measures Kick In

    HM Revenue and Customs has assumed new powers to tackle tax fraud and evasion as key parts of new legislation take effect, including tougher rules on construction industry schemes and penalties for promoters of tax avoidance arrangements. Correction: A previous version of this article misstated which HMRC reforms took effect on April 6. The error has been corrected.

  • April 06, 2026

    Chewy Investor Settles Suit Against BC Partners For $29.5M

    A Chewy Inc. investor has brokered a $29.5 million deal with BC Partners that, if finalized, would settle the investor's derivative suit that alleged BC Partners saddled Chewy investors with potential tax liabilities following a financially unfair downstream merger involving PetSmart Inc., the parties told the Delaware Chancery Court on Monday.

  • April 06, 2026

    IRS' Proposed Voluntary Disclosure Rule Could Be Dissuasive

    The IRS has proposed relaxing the 75% civil fraud penalty for participants in its voluntary disclosure program, but a corresponding 90-day deadline for complying with all payment and filing requirements could discourage some taxpayers from coming forward.

  • April 06, 2026

    Germany, Italy Ask EU For Windfall Tax On Energy Companies

    Germany, Italy, Spain, Austria and Portugal have asked the European Union to create a windfall profits tax on energy companies so governments can finance relief for spiking oil prices fueled by the U.S. and Israel's war with Iran, the EU and three finance ministries told Law360 on Monday.

  • April 06, 2026

    Activewear Co. Fabletics Sued Again For Tariff Refunds

    Fabletics, the activewear company cofounded by actress Kate Hudson, was hit with a proposed class action in California federal court Friday alleging it is improperly pocketing tariff surcharges from customers and is refusing to commit to refunds, weeks after a similar suit was filed in Illinois state court.

  • April 06, 2026

    Int'l Tax In March: Tariff Refunds Coming Amid New Disputes

    Tariffs dominated the headlines in March, with the process for refunding those illegally imposed under the International Emergency Economic Powers Act being set up — and customers demanding their cut from businesses. Here, Law360 looks at these and other international tax developments from last month.

  • April 03, 2026

    Iran War's Trade Fallout Likely To Spread Beyond Oil, Fertilizer

    The war in Iran has already shocked oil and gas prices worldwide and stakeholders expect further U.S. trade consequences related to the conflict including supply chain constraints, cost increases across a variety of goods, and industries and new geopolitical responses as the conflict continues.

  • April 03, 2026

    Australia Cuts Fuel Tax Further As Iran War Spikes Prices

    Australia will reduce its fuel excise tax by nearly 11% on top of an already halved rate to offer consumers relief as oil prices have spiked in the wake of the U.S. and Israel's war in Iran, Prime Minister Anthony Albanese said.

  • April 03, 2026

    Man Denies Owing Gov't $19M In Biofuel Tax Credit Fraud

    A businessman told a Utah federal court that he shouldn't need to pay over $19 million for a forfeited loan from a company central to a $511 million biofuel tax credit fraud because the government's calculations are unjust and a government asset tricked him into withholding payment.

  • April 03, 2026

    Law360 Announces The Members Of Its 2026 Editorial Boards

    Law360 is pleased to announce the formation of its 2026 Editorial Advisory Boards.

  • April 03, 2026

    Taxation With Representation: Cleary, Hogan Lovells, Wachtell

    In this week's Taxation With Representation, spice maker McCormick acquires Unilever's foods business, wholesale restaurant food distributor Sysco buys Jetro Restaurant Depot, and private equity giant KKR closes a fund focused on investments in North America.

  • April 03, 2026

    EU Steel Group Says Carbon Tax Rules Need Tightening

    A European steel association urged policymakers Friday to close what it said are loopholes in the European Union's carbon tax system, arguing that legislative tweaks proposed by the bloc fall short.

  • April 02, 2026

    US Tariffs Hiked Consumer Prices By 0.5% To 1%, Report Says

    The U.S. government's tariffs imposed last year likely raised consumer prices by 0.5% to 1%, the Yale Budget Lab said Thursday in a report that revised down its initial estimates.

  • April 02, 2026

    Inheritance Tax Changes To Hit Investment, Advisers Warn

    The U.K. government's plans to slash tax relief for inheritance tax on agricultural and business property coming into effect Monday will hit investors and family businesses, advisers told Law360.

  • April 02, 2026

    $3.6T Of Untaxed Personal Wealth Held Offshore, Oxfam Says

    About $3.6 trillion in untaxed household wealth was held offshore in 2024, exceeding the poorer half of humanity's combined wealth by about $1 trillion, Oxfam International reported Thursday.

  • April 02, 2026

    Germany Moves To Cut Passenger Tax After Outcry By Airlines

    Germany advanced a proposal to slash an air passenger tax in an effort to improve the competitiveness of its aviation industry, walking back a 2024 rate hike.

  • April 02, 2026

    Investors Settle £4.3M Case Against Tax Refund Lender

    Two investment companies that sued a tax refund lender and its directors for more than £4.3 million ($5.7 million) in unpaid debt have agreed to settle their case.

  • April 01, 2026

    Apple's Top Irish Branch Had $1.4B Minimum Tax Bill In 2025

    Apple's top subsidiary in Ireland had a $1.4 billion top-up tax liability under the 15% global minimum tax during its 2025 fiscal year, part of a $12.1 billion tax bill, according to its annual financial statement.

  • April 01, 2026

    EU, Gibraltar Advance Deal With Intro Of Transaction Tax

    European Union countries advanced a post-Brexit deal concerning the British overseas territory of Gibraltar on Wednesday, which includes the introduction of a transaction tax to reduce competitive distortions with Spain, according to a Council of the EU news release.

  • April 01, 2026

    HMRC Absorbs Valuation Office Ahead Of Mansion Tax

    Britain's Valuation Office Agency has been integrated into a new branch of HM Revenue and Customs before the rollout of a new tax on high-value homes, the tax authority said Wednesday.

Expert Analysis

  • AI-Generated Doc Ruling Guides Attys On Privilege Risks

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    A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.

  • The Law Firm Merger Diaries: Leadership Strategy After Day 1

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    For law firm leaders, ensuring a newly combined law firm lives up to its promise, both in its first days of operation and well after, includes tough decisions, clear and specific communication, and cheerleading, says Peter Michaud at Ballard Spahr.

  • Calif.'s Civility Push Shows Why Professionalism Is Vital

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    The California Bar’s campaign against discourteous behavior by attorneys, including a newly required annual civility oath, reflects a growing concern among states that professionalism in law needs shoring up — and recognizes that maintaining composure even when stressed is key to both succeeding professionally and maintaining faith in the legal system, says Lucy Wang at Hinshaw.

  • US-Ukraine Reconstruction Fund Tax Exemptions Uncertain

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    Tax provisions in the bilateral agreement to establish the U.S.-Ukraine Reconstruction Investment Fund, which recently announced it is accepting applications, are so broad and imprecise as to leave uncertainty regarding whether and when tax exemptions will apply to investors' income, say attorneys at Avellum and Debevoise.

  • Trivia Competition Makes Me A Better Lawyer

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    Playing trivia taught me to quickly absorb information and recognize when I've learned what I'm expected to know, training me in the crucial skills needed to be a good attorney, and reminding me to be gracious in defeat, says Jonah Knobler at Patterson Belknap.

  • Judges On AI: Practical Use Cases In Chambers

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    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.

  • Malpractice Claim Assignability Continues To Divide Courts

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    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.

  • NYC Bar Opinion Warns Attys On Use Of AI Recording Tools

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    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.

  • 4 Quick Emotional Resets For Lawyers With Conflict Fatigue

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    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.

  • Judges On AI: How Judicial Use Informs Guardrails

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    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.

  • Key False Claims Act Trends From The Last Year

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    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.

  • Hosting Exchange Students Makes Me A Better Lawyer

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    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.

  • How A 1947 Tugboat Ruling May Shape Work Product In AI Era

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    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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