International
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January 07, 2026
IRS Mulling Budget Bill's Changes To CFC Rules, Official Says
The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.
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January 07, 2026
Irish Tax Revenue Up €8.6B In 2025, Corp. Taxes Up 17%
The Irish government saw tax revenue rise by €8.6 billion ($10 billion) in 2025, with corporate tax receipts up by 17.2%, the Department of Finance said in its annual report.
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January 07, 2026
Portuguese Tax System Too Complex, OECD Says
The Portuguese government needs to simplify the country's tax regime to boost economic growth and raise living standards, the Organization for Economic Cooperation and Development said Wednesday.
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January 07, 2026
IRS Outlines Process For PFICs Seeking Retroactive Elections
The Internal Revenue Service set out requirements Wednesday for passive foreign investment corporations seeking rulings to allow them to make retroactive qualified electing fund elections.
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January 06, 2026
IRS Appeals Pause Of ICE Info-Sharing Agreement
The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.
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January 06, 2026
Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules
A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasion that would justify the regulations.
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January 06, 2026
Thai Cabinet OKs Changes To Aid Satisfying Global Min. Tax
Thailand's Cabinet has approved draft legislation aimed at helping companies comply with the 15% global minimum tax, the country's tax authority said.
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January 06, 2026
Uber Changes UK Contracts Over New Minicab VAT Rules
Uber has changed its contracts with its British drivers to reclassify itself as an agent, a move that will save it from collecting value-added tax on fares, just before the U.K.'s overhaul of tax rules for the minicab sector took effect.
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January 06, 2026
Ireland Offers Europe's First Tax Break For Unscripted Shows
Ireland is offering a corporate tax credit for unscripted productions that promote Irish and European culture, the Department of Finance said, noting that the initiative is the first of its kind in Europe.
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January 06, 2026
Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team
After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on the tax elements of mergers and acquisitions.
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January 05, 2026
Md. Railway Distributor Exec Sued Over Alleged Asset Looting
Chinese railway equipment manufacturer Anyang Railway Equipment Co. Ltd. has filed suit in Maryland federal court, claiming the sole executive and majority shareholder of a railway distribution company, in which Anyang is also a shareholder, looted corporate assets for personal gain and excluded Anyang from management decisions, among other things.
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January 05, 2026
EU Sets Default Emission Levels For Carbon Border Tax
The European Union released default levels of greenhouse gas emissions that importers must use to calculate liabilities for the newly enforced carbon border adjustment mechanism when they lack reliable information on the emissions associated with producing covered products.
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January 05, 2026
Countries Reach Deal To Exempt US From Pillar 2 Tax
Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.
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January 05, 2026
ECJ To Mull Parent-Subsidiary Directive's Tax Impact
The European Union's top court will rule on the tax implications of the EU's parent-subsidiary directive for a loss-making company in Germany following a request from the country's finance court, according to a Monday notice.
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January 05, 2026
Gibson Dunn Adds Sidley Tax Pro In Silicon Valley
Gibson Dunn & Crutcher LLP announced Monday that it has bulked up its tax practice group with a partner in Palo Alto, California, who previously co-led the global tax practice and headed up the West Coast tax group at Sidley Austin LLP.
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January 02, 2026
Busy DOJ Tax Atty Seeks More Time In 7th Circ. AbbVie Case
A U.S. Department of Justice tax attorney asked the Seventh Circuit on Friday for another extension to file an opening brief in a dispute over AbbVie's $1.6 billion payment to an Irish biotechnology company, citing staffing shortages and internal procedural requirements.
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January 02, 2026
IRS Floats Updates To Fee Paid By Brand Drugmakers
The Internal Revenue Service floated updates to regulations governing how branded prescription drug manufacturers or importers should calculate an annual fee established by the Affordable Care Act, a move the agency said aims to incorporate changes in drug discount programs and clarify tax reporting.
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January 02, 2026
Federal Tax Policy To Watch In 2026
Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.
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January 02, 2026
Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
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January 02, 2026
European Tax Policy To Watch In 2026
The European Union may have to take a more independent line on international tax in 2026 as it tackles policies such as the minimum corporate tax, but its success will likely depend on how it deals with opposition to such policies from the U.S. administration. Here, Law360 looks at important European tax developments to watch for the coming year.
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January 02, 2026
Top International Tax Policy To Watch In 2026
The details of a proposed U.S. exemption from the global minimum tax's international provisions, possible retaliatory measures by the U.S. government and the rollout of major changes in Congress' latest budget are high priority for tax professionals going into 2026. Here, Law360 previews international tax practitioners' top priorities for the coming year.
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January 02, 2026
Top International Tax Cases To Watch In 2026
Major multinational corporations such as McKesson and Coca-Cola will continue to litigate high-stakes international tax cases in 2026, including transfer pricing disputes with billions of dollars on the line and fights over whether regulations exceed the government's authority. Here, Law360 looks at four key international tax cases to follow in the new year.
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January 01, 2026
4 High Court Cases To Watch This Spring
The U.S. Supreme Court justices will return from the winter holidays to tackle several constitutional disputes that range from who is entitled to birthright citizenship to whether transgender individuals are entitled to heightened levels of protection from discrimination.
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January 01, 2026
Blue Slip Fight Looms Over Trump's 2026 Judicial Outlook
In 2025, President Donald Trump put 20 district and six circuit judges on the federal bench. In the year ahead, a fight over home state senators' ability to block district court picks could make it more difficult for him to match that record.
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January 01, 2026
BigLaw Leaders Tackle Growth, AI, Remote Work In New Year
Rapid business growth, cultural changes caused by remote work and generative AI are creating challenges and opportunities for law firm leaders going into the New Year. Here, seven top firm leaders share what’s running through their minds as they lie awake at night.
Expert Analysis
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A Look At A Possible Corporate Transparency Act Exemption
Attorneys at Kirkland offer a deep dive into the application of the Corporate Transparency Act's reporting requirements specifically to U.S.-domiciled co-issuers in typical collateralized loan obligation transactions, and consider whether such issuers may be able to assert an exemption from the CTA's reporting requirements.
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Inconsistent Injury-In-Fact Rules Hinder Federal Practice
A recent Third Circuit decision, contradicting a previous ruling about whether consumers of contaminated products have suffered an injury in fact, illustrates the deep confusion this U.S. Supreme Court standard creates among federal judges and practitioners, who deserve a simpler method of determining which cases have federal standing, says Eric Dwoskin at Dwoskin Wasdin.
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In-House Counsel Pointers For Preserving Atty-Client Privilege
Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.
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Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example
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.
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Accountant-Owned Law Firms Could Blur Ethical Lines
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.
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AI Will Soon Transform The E-Discovery Industrial Complex
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.
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Unpacking The Legal Foundation Of Trump's New Trade War
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.
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When Innovation Overwhelms The Rule Of Law
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.
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Imagine The Possibilities Of Openly Autistic Lawyering
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.
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Litigation Funding Disclosure Debate: Strategy Considerations
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.
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5 Ways To Create Effective Mock Assignments For Associates
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.
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Mentorship Resolutions For The New Year
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.
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Tax Directive Marks Milestone In Harmonizing EU System
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.