International

  • October 30, 2026

    Hedge Fund Exec Fights $40M In IRS Foreign Reporting Fines

    A hedge fund manager is seeking to recover nearly $40 million in foreign account reporting penalties, telling the U.S. Court of Federal Claims that the IRS violated his due process rights and administrative rules in imposing fines linked to his bankrupt Texas tycoon father's international accounts.

  • October 30, 2026

    Brookfield Fights $4.3M Tax Bill Over Lehman Losses

    Asset management giant Brookfield is challenging a $4.3 million tax bill tied to its acquisition of a defunct Lehman Brothers unit, telling the U.S. Tax Court that the IRS incorrectly denied a deduction stemming from the Lehman affiliate's losses.

  • October 30, 2026

    EU, Canada Seal Digital Trade Deal Amid Closer Partnership

    EU and Canadian officials signed a document Friday concluding negotiations on a digital trade agreement between the two economies following a summit in Montreal where Canadian and European leaders shared new details about efforts to strengthen their economic and diplomatic ties.

  • October 30, 2026

    Countries Want OECD Plan To Tax Digital Economy

    The Organization for Economic Cooperation and Development has been tasked with creating a plan to continue work on taxing the digital economy by countries that participate in its global tax policymaking body, the organization said Friday.

  • October 30, 2026

    Int'l Tax In October: UK Targets Banks, US Nixes Spinoff Rule

    The U.K. government issued its first budget under a new prime minister in October and is looking to the banking industry to boost revenue, while in the U.S., a dispute over a Minnesota medical device company's pricing with a Puerto Rican affiliate could require a third Tax Court trial after settlement talks failed. Here, Law360 looks at the top international tax developments from the past month.

  • October 30, 2026

    Buchalter Adds Tax Pro In Dallas From Jackson Walker

    Buchalter PC's rapid growth in Texas continues with the addition of a Dallas-based tax partner who came aboard from Jackson Walker LLP.

  • October 30, 2026

    2 In Merseyside Jailed Over £8.5M Teeth-Whitening VAT Scam

    Two men from Merseyside, England, who stole more than £8.5 million ($11.4 million) in tax from the sale of dangerous teeth-whitening products were sentenced to over four years each in prison, Britain's tax authority said Friday.

  • October 30, 2026

    Taxation With Representation: Kirkland, Gibson Dunn, Cravath

    In this week's Taxation with Representation, Blackstone, Bank of America, Citi and Morgan Stanley announce a financing structure to buy Broadcom artificial intelligence chips and network components for Anthropic, EQT acquires Range Resources to create a powerhouse natural gas company, and DoorDash buys Instacart.

  • October 30, 2026

    HMRC Sets Out Penalties For Promoting Tax Schemes

    HM Revenue & Customs set out new penalties for promoters of certain tax avoidance schemes in guidance published Friday.

  • October 30, 2026

    Canada Tax Court Largely Lets PE Fund Shield EY Docs

    A private equity fund can mostly use attorney-client privilege to shield documents concerning its tax strategy that were created by EY for the fund's law firm, the Tax Court of Canada said in a fight over whether an anti-avoidance rule applies to the fund's financing.

  • October 29, 2026

    Treasury Asked To Narrow Crackdown On Fund Strategies

    The U.S. Treasury Department should develop targeted rules distinguishing abusive transactions from long-standing investment management practices in new enforcement that scrutinizes novel strategies exploiting the tax benefits of certain investment vehicles and financial products, firms and organizations told the department.

  • October 29, 2026

    German Co. Says $1.2M IRS Tax Bill Rests On Invalid Rule

    A German manufacturer challenging a $1.2 million tax bill stemming from late information filings with the IRS told the U.S. Tax Court it should be able to claim deductions and credits despite missing the statutory due date, saying the agency applied a rule that is procedurally invalid under federal law.

  • October 29, 2026

    US Expatriations In Q3 Down 16% From Last Year, IRS Says

    The number of people who lost or renounced their U.S. citizenship totaled more than 1,300 in the third quarter of 2026 as logged by the U.S. Department of the Treasury, down about 16% year over year and 25% from the previous quarter, the IRS said Thursday.

  • October 29, 2026

    Frasers Unit Loses £5.6M VAT Dispute Over Marketing Photos

    A Frasers Group unit lost its bid to overturn assessments that it owed value-added tax of £5.6 million ($7.4 million) when a London court ruled that the company's marketing photos were linked to taxable retail sales and consumer credit.

  • October 29, 2026

    Tax Consultancy Asks 5th Circ. To Kill Microcaptive Rule

    The IRS never published data showing that microcaptive transactions pose a potential for tax avoidance to justify a rule making companies and advisers report them as "transactions of interest," a tax consultancy seeking the rule's demise told the Fifth Circuit.

  • October 29, 2026

    Wyo. Court Flags AI Use In Defamation Case Against Tax Atty

    A Wyoming federal judge threatened sanctions against an exiled U.K. financial services provider who is suing a tax attorney for defamation, noting the businessman's filings indicate the use of artificial intelligence and potential perjury regarding his residency status.

  • October 29, 2026

    FCA Urged To Probe Possible Leak Of Bank-Tax Budget Plans

    The parliamentary Treasury Committee asked HM Treasury and the Financial Conduct Authority on Thursday to investigate whether confidential details of the government's planned bank tax increase were improperly disclosed before the Budget speech on Wednesday.

  • October 28, 2026

    Canada Court Won't Block Plan To Pull Group's Charity Status

    A Canadian appeals court denied an organization's request to halt revenue collectors' plan to revoke its charitable status, holding that the group failed to show it would suffer irreparable harm if the agency publicly disclosed the revocation.

  • October 28, 2026

    Pitney Bowes Denied Interest In Repatriation Tax Fight

    The IRS doesn't owe interest to Pitney Bowes for overpaid 2017 federal income taxes, the U.S. Court of Federal Claims held, finding the agency was allowed to apply a chunk of the overpayment to the global shipping and logistics company's repatriation tax liability.

  • October 28, 2026

    Texas Instruments Asks Court To Reject IRS Stance On FDII

    The IRS' reduction of Texas Instruments' deduction for foreign-derived intangible income contradicted a long-standing interpretation by courts, which have required a connection between expenses and gross income for which a deduction is allowed, the company told the U.S. Tax Court.

  • October 28, 2026

    Microsoft Seeks $115M NJ Refund Over GILTI Apportionment

    New Jersey unconstitutionally apportioned Microsoft's global intangible low-taxed income by failing to account for the activities of foreign entities that generated those earnings, the company argued in asking the state tax court to award it a $114.6 million corporate tax refund.

  • October 28, 2026

    UK Director Owes Tax On Shuffled Debt, Tribunal Affirms

    The moving of a roughly £513,000 ($684,000) loan a U.K. director owed his company to its parent holding company still counts as a release of the loan, a London court affirmed Wednesday, sticking the director with an additional £195,000 in income tax.

  • October 28, 2026

    Exec Can't Shake AU$17M Tax Settlement, Court Says

    A director cannot appeal his liability for judgment under a roughly AU$17 million ($12 million) settlement deed linked to tax fraud allegations against his companies because his challenge had no merit, was filed late and lacked supporting evidence, the Supreme Court of New South Wales said Wednesday.

  • October 28, 2026

    ABA Urges Treasury To Drop 1040 Citizenship Question

    The American Bar Association's Tax Section urged the U.S. Department of the Treasury to remove a proposed citizenship status question from individual tax returns, saying it has no stated purpose and is not connected to any tax-related eligibility determination.

  • October 28, 2026

    Judge Sides With Feds In Pair's $1.6M Tax Penalty Dispute

    A formerly married couple are not entitled to claim a refund of roughly $1.6 million for tax penalties related to a foreign trust, a Pennsylvania federal magistrate judge ruled, finding the court lacks jurisdiction because they failed to demonstrate they properly filed a refund claim.

Expert Analysis

  • Calif. Bill Goes Too Far In Trying To Regulate Attorney AI Use

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    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.

  • Attorneys Using AI May Have Ethical Duty To Redact Docs

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    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.

  • Md. Court Got Ad Tax Similarity Analysis Wrong

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    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.

  • Taekwondo Makes Me A Better Lawyer

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    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.

  • OECD Draft Could Guide Pricing For Intragroup R&D Deals

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    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.

  • Monitor Exposure, Stay Flexible Amid Tariff Uncertainty

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    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.

  • Being In A Band Made Me A Better Lawyer

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    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.

  • The Divergent Approaches In US, EU Forced Labor Standards

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    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.

  • Going To Hardcore Shows Makes Me A Better Lawyer

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    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.

  • Handling Section 301 Tariffs When CBP Detains Goods

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    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.

  • Judges On AI: Examining Administrative, Organizational Uses

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    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.

  • Being A Magician Makes Me A Better Lawyer

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    The skills I've developed as a lifelong magician have translated directly into tangible benefits in the courtroom because performing magic and trying cases both live at the intersection of psychology, storytelling, timing and disciplined rehearsal, says Mark Dombroff at Fox Rothschild.

  • Choral Singing Makes Me A Better Lawyer

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    Singing in the New York City Bar Chorus — a hobby partly inspired by the late U.S. District Judge Richard Owen, who infused my clerkship year with opera music — has improved my legal career by refining my abilities to listen, exude confidence and develop emotional intelligence, says Bonnie Baker at Friedman Kaplan.

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