International
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November 05, 2026
Treasury Seeks Input On IRS' Info Requests For Treaty Cases
The U.S. Treasury Department asked multinational corporations Thursday to weigh in on ways the IRS could ease compliance burdens companies face when providing information to agency during U.S. tax treaty disputes.
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November 05, 2026
MVP: Wachtell Lipton's Eiko Stange
Eiko Stange, a member of Wachtell Lipton Rosen & Katz's tax practice, was lead counsel on OpenAI's corporate restructuring and recapitalization, advised Honeywell on its aerospace business's $72 billion spinoff and oversaw the tax implications of Unilever's $44 billion combination with McCormick, earning him a spot as one of the 2026 Law360 Tax MVPs.
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November 05, 2026
Virgin Islands Tax Agency Denied Redo In NIIT Dispute
A U.S. Virgin Islands federal judge declined to rethink his order holding that the territory's residents are exempt from the net investment income tax, ruling that local revenue collectors' disagreement with his reasoning is not grounds for reconsideration.
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November 05, 2026
FCA Stops Collector Chasing Workers For Tax Scheme Loans
The financial watchdog said Thursday that it has prevented a debt collection firm from pursuing workers for repayment of tax avoidance scheme loans, after the debts were sold to a company that is not authorized by the regulator.
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November 05, 2026
Faegre Drinker Hires Morgan Lewis Tax Specialist In Philly
Faegre Drinker Biddle & Reath LLP has hired a Morgan Lewis & Bockius LLP tax associate to join its Philadelphia office as a partner working on federal income tax and other tax matters, according to a Wednesday announcement.
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November 04, 2026
Illinois Tool Co. Disputes $26M Tax Bill, Seeks $32M Refund
The IRS erred in denying a $739 million capital loss to an Illinois tool company as well as determining it owes more than $26 million in taxes for 2019 through 2021 and denying its request for a $32 million refund for those years, it told the U.S. Tax Court.
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November 04, 2026
Hong Kong Couple Get 7 Years For €10M VAT Fraud
A German court sentenced a Hong Kong couple to seven years in prison following their conviction for a €10.3 million ($11.6 million) value-added tax evasion scheme, European Union authorities said Wednesday.
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November 04, 2026
Tribunal Largely Backs HMRC Ax Of Port Co.'s £57M Tax Break
The First-tier Tribunal erred in deciding that HM Revenue & Customs could not deny Liverpool's port operator tax allowances on £57.1 million ($76.9 million) spent building part of a deep-water container terminal, the Upper Tribunal found Wednesday.
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November 04, 2026
Dead Man's $2M FBAR Penalty Is Reasonable, 9th Circ. Told
The $2 million in civil penalties imposed on a dead man for violating foreign bank account reporting rules when he was alive is not excessive, the U.S. government told the Ninth Circuit in a bid to collect the penalties from his estate.
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November 04, 2026
UK Biz Wins Fresh Look At Collagen Product's VAT Status
A court must look again at whether a U.K. company's liquid collagen product is a drink for human consumption, and therefore a zero-rated food for value-added tax purposes, in light of an appeals court's ruling in a separate case, a London tribunal said in a decision published Wednesday.
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November 04, 2026
MVP: Paul Weiss' Brian Krause
Paul Weiss Rifkind Wharton & Garrison LLP partner Brian Krause assisted drug company Metsera in its up-to-$10 billion acquisition by Pfizer and served as the lead tax counsel during Keurig Dr Pepper's $18.4 billion acquisition of coffee company JDE Peet's, earning him a place among the 2026 Law360 Tax MVPs.
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November 04, 2026
Countries Close Record Number Of Tax Cases, OECD Says
Tax administrations around the world resolved nearly 3,000 cross-border corporate tax disputes in 2025, the highest number recorded to date, the Organization for Economic Cooperation and Development said Wednesday.
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November 04, 2026
Hong Kong Enacts Digital Asset Reporting Legislation
The Hong Kong government passed legislation Wednesday that will implement an international digital asset transparency framework to help tax officials collect and share cryptocurrency data.
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November 04, 2026
EU Digital Tax Proposal Saved From Legislative Cull
The European Commission decided not to ax a digital services tax proposal in its 2027 work program despite a lack of progress, according to a final version of its agenda for the coming year seen Wednesday by Law360.
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November 03, 2026
Tax Court Hears From Eaton's Former Islands Plant Manager
A longtime Eaton Corp. plant manager described for the U.S. Tax Court on Tuesday some of the components and functions of the circuit breakers manufactured in Puerto Rico and the Dominican Republic that the company maintains were so critical to its success.
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November 04, 2026
High Court Says Uber Owes Payroll Tax On Driver Payments
The High Court of Australia on Wednesday ruled 6-1 to uphold a ruling that drivers "supply" driving services to rideshare giant Uber, finding the drivers' contracts with the company are relevant contracts under New South Wales payroll tax law, meaning Uber's payments to drivers attract payroll tax.
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November 03, 2026
EU Ready To Abandon Tax Bills Falling Short Of Unanimity
The European Commission plans to withdraw a series of tax initiatives stuck in the legislative pipeline because the bills are not able to secure the support of all member states, according to a draft of its 2027 work program seen Tuesday by Law360.
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November 03, 2026
EU Tax Reporting Break Would Send 'Worst Signal,' Panel Told
Multinational companies shouldn't get a free pass on reporting potentially harmful cross-border tax arrangements to European Union countries because they're within the scope of the 15% global minimum tax, an EU lawmaker leading committee discussions on the proposal said Tuesday.
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November 03, 2026
£3M In Taxes Axed In Fight Over 'Gaming Machine' Definition
A London appeals court struck down HM Revenue & Customs' nearly £3.3 million ($4.4 million) in tax assessments against arcade and bingo hall operators, holding the companies had justifiable grounds for misunderstanding the revenue collector's guidance on what constitutes a "gaming machine."
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November 03, 2026
MVP: Debevoise's Peter Schuur
Peter Schuur, chair of Debevoise & Plimpton LLP's global tax practice, steered the tax strategy for Warner Bros. Discovery's $110 billion sale to Paramount Skydance, earning him a spot as one of the 2026 Law360 Tax MVPs.
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November 03, 2026
EU Official Defends US Exclusion From Reporting Carveout
Member states currently negotiating the European Union's tax simplification proposals should not allow U.S.-headquartered companies operating under the side-by-side agreement of the global minimum tax framework to benefit from the full breadth of the initiatives, a European Commission official said Tuesday.
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November 03, 2026
Latham Hires Tax Partner In DC From Morgan Lewis
Latham & Watkins LLP has hired a former Morgan Lewis & Bockius LLP partner who spent 16 years with his previous firm working on tax and employee benefits issues.
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November 03, 2026
Former Ecclestone Family Lawyer Denies Tax Fraud Charge
A former solicitor and adviser to Bernie Ecclestone, the ex-chief executive of Formula One, pleaded not guilty to tax fraud in London on Tuesday over allegations that he lied to HM Revenue and Customs about his ability to pay back taxes.
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November 02, 2026
Xbox Buyer's Microsoft Tariff Refund Suit Sent To Arbitration
A Washington federal judge said Monday that an Xbox buyer must arbitrate his claims that Microsoft unjustly pocketed refunds meant for consumers after the U.S. Supreme Court struck down the Trump administration's global tariff regime, citing an arbitration pact described by the console's packaging and included documents.
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November 02, 2026
Eaton Atty Says Island Plants' Activities Critical To Success
The skilled manufacturing that took place at Eaton's plants in Puerto Rico and the Dominican Republic from 2011 through 2013 was the critical factor in the success of the company's electrical breaker products business, an attorney for Eaton Corp. told the U.S. Tax Court on Monday.
Expert Analysis
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Playing Bid Whist Makes Me A Better Lawyer
As a child, I viewed bid whist as a family tradition and a source of friendly card game competition, but as a lawyer, I see it as a tool that has helped me cultivate skills like communication, teamwork, risk assessment and composure, says Keyonn Pope at Riley Safer.
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Md. Digital Tax Ruling Is A Road Map For Future Challenges
Three Maryland Tax Court rulings that recently struck down the state's digital advertising tax suggest constitutional and statutory vulnerabilities that could be used to challenge newly enacted digital services laws or legislation being considered by other states, say attorneys at Holland & Knight.
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Calif. Bill Goes Too Far In Trying To Regulate Attorney AI Use
California’s first-in-the-nation act regulating how attorneys and arbitrators use generative artificial intelligence will likely soon become law, but read broadly, the provisions may dissuade lawyers from employing AI at all, thereby depriving them of key work tools, says Joshua Wurtzel at Schlam Stone.
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Attorneys Using AI May Have Ethical Duty To Redact Docs
The trajectory of legal ethics guidance in recent years strongly suggests that as redaction technology becomes more accessible, the failure to use it when uploading highly confidential materials into artificial intelligence tools will become increasingly difficult to defend as reasonable, say attorneys at Lewis Brisbois.
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Md. Court Got Ad Tax Similarity Analysis Wrong
Decisions striking Maryland’s digital advertising tax are fundamentally flawed because the Maryland Tax Court found similarity between digital ads and other ads without considering deep market distinctions, says Darien Shanske at UC Davis School of Law.
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Taekwondo Makes Me A Better Lawyer
Taekwondo has taught me to recognize when to fight for a position and when to focus on finding a solution, and that the best outcomes are often achieved by solving problems — all of which has improved my work as a bankruptcy lawyer, mediator and Subchapter V trustee, says Amy Denton Mayer at Berger Singerman.
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OECD Draft Could Guide Pricing For Intragroup R&D Deals
The Organization for Economic Cooperation and Development's proposed revisions to its intragroup transfer pricing guidelines provide helpful tips for determining the cost base for contract research and development services, highlighting the importance of selecting a reasonable set of third-party comparables and appropriate means for evaluating markups, says economist Harold McClure.
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Monitor Exposure, Stay Flexible Amid Tariff Uncertainty
To navigate an unstable trade environment, businesses must evaluate their exposure to new tariffs invoked under a patchwork of statutory authorities and be prepared to adapt to further changes that may be on the horizon, says Bhargav Prajapati at Capital Trade.
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Being In A Band Made Me A Better Lawyer
Playing shows in storied New York City venues and rehearsing with my bandmates in poorly ventilated rooms helped develop the professional qualities I rely on as a litigator, including an ability to collaborate with strong-minded equals and the determination to treat each client with singular focus, says Eliad Shapiro at Herrick Feinstein.
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The Divergent Approaches In US, EU Forced Labor Standards
Forced labor guidance documents recently issued by the U.S. and the European Union have meaningful differences, with the U.S. taking a documentary approach to compliance and the EU emphasizing human rights risks as a governance challenge, but one model will likely exert greater influence, say attorneys at Steptoe.
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Going To Hardcore Shows Makes Me A Better Lawyer
While government contracts law and the hardcore scene may seem entirely unrelated, in my experience, both are about community, focus, being prepared for the unexpected and managing chaos, says Isaac Natter at Fluet.
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Handling Section 301 Tariffs When CBP Detains Goods
Importers subject to Section 301 tariffs on goods under a U.S. Customs and Border Protection forced labor hold should consider three approaches when deciding whether to pay tariffs on goods that may ultimately be excluded, or wait and watch port demurrage compound daily, says James Ferry at Ferry Trade.
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Judges On AI: Examining Administrative, Organizational Uses
U.S. District Judge Alan Albright of the Western District of Texas examines how artificial intelligence could transform a court's ability to deal with administrative work and organize materials when preparing for hearings or drafting opinions, thereby affording judges more time to resolve contested issues.