International

  • October 31, 2025

    OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases

    Tax authorities began more than 2,500 mutual agreement procedure cases last year involving transfer pricing, a record number representing a 29% increase from the previous year, the Organization for Economic Cooperation and Development said Friday.

  • October 31, 2025

    Taxation With Representation: Skadden, Davis Polk

    In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.

  • October 31, 2025

    Australia Issues Guidance On Public Country-By-Country Law

    Australia issued guidance Friday on how to comply with its public country-by-country reporting law, including filing instructions, formatting and the information required to be disclosed.

  • October 31, 2025

    5 Indicted In Germany In €188M VAT Fraud Scheme

    Five German residents have been indicted on charges related to their participation in a €188 million ($217 million) value-added tax fraud scheme, European Union authorities said Friday.

  • October 30, 2025

    Trade Deals At Risk In Trump Tariff Case, Feds Tell Justices

    The federal government told the U.S. Supreme Court on Thursday that President Donald Trump's global tariffs have led to significant trade deals addressing the underlying national emergencies he declared, and a ruling determining them unlawful would prove catastrophic.

  • October 30, 2025

    China Delays Expanded Mineral Export Controls, Trump Says

    China has agreed to delay for a year an expansion to export controls for key minerals and is set to start purchasing more U.S. agricultural products including soybeans, while U.S. tariffs on Chinese goods will decrease 10%, President Donald Trump said early Thursday morning.

  • October 30, 2025

    Senate Votes To Ax Global Tariffs, But House Path Blocked

    The Senate passed legislation Thursday to end the declared national emergency propping up President Donald Trump's global tariff regime shortly after passing similar bills regarding tariffs on Canada and Brazil, though the House previously moved its deadline for action on the matter to next year.

  • October 30, 2025

    IRS Discloses Record In ICE Data Sharing Case

    The IRS, following a judge's order, has released its administrative record in a lawsuit over its agreement to share taxpayer information with federal immigration authorities, including emails in which officials discuss U.S. Immigration and Customs Enforcement's request for information on nearly 1.3 million taxpayers.

  • October 30, 2025

    French Legislators Vote To Double Digital Services Tax To 6%

    Lawmakers in the lower house of France's Parliament voted to double the country's digital services tax rate from 3% to 6%, stopping short of an earlier proposal to increase the measure to 15% to mirror U.S. tariffs.

  • October 30, 2025

    Dutch Centrist Party Gains Seats With Tax Change Agenda

    The centrist party Democrats 66 looks set to come out of the Dutch general election as the party best placed to lead the next government with an agenda to cut taxes for working people and raise rates on wealth and pollution, according to balloting counted Thursday.

  • October 30, 2025

    EU's Top Court Axes Dutch Co.'s Challenge Against Pillar 2

    The European Union's top court declined Thursday to revive a Dutch company's case against an EU directive that implements an international minimum tax agreement known as Pillar Two, holding that the business lacked standing to challenge the law.

  • October 29, 2025

    Senate Backs Axing Brazil Tariffs, But House Vote Blocked

    The Senate voted to end a declared national emergency underpinning U.S. tariffs placed on Brazil for the prosecution of its former president over an attempted coup, but the House has delayed a statutory requirement to expedite accompanying legislation.

  • October 29, 2025

    Tribunal Walks Back HMRC's £1M Share Sale Decision

    HM Revenue & Customs incorrectly increased a man's income tax liability by over £1 million ($1.3 million) on the sale of shares in a company as part of his retirement plan, a London tribunal ruled.

  • October 29, 2025

    IRS Wrongly Nixed Insurance Transactions, Tax Court Told

    A Tennessee company that claims to provide in-house insurance to businesses supporting the U.S. Department of Defense and NATO has challenged more than $500,000 in tax liabilities and the IRS' denial of its status as an insurer, according to a U.S. Tax Court petition.

  • October 29, 2025

    Publix Heiress Asks To Quash IRS Summons For Bank Info

    An heiress to the Publix grocery store chain asked a Florida federal court to quash an IRS summons seeking her bank information on behalf of Italian tax officials, arguing that the agency's request flouts the Italy-U.S. tax treaty.

  • October 29, 2025

    Top UK Court Rules NHS Parking Services Subject To VAT

    Britain's top court ruled Wednesday that provision of car parking services by a National Health Service trust should not be exempt from value-added tax, a decision that will affect dozens of stayed appeals by NHS entities worth up to £100 million ($132 million).

  • October 28, 2025

    Baltimore Atty Found Personally Liable For Entity's Taxes

    A Baltimore attorney who manages a client's holding company is personally responsible for paying the entity's unpaid taxes, a Maryland federal judge said, finding that he approved and oversaw loan transactions that prompted the IRS to seek $2 million from the entity.

  • October 28, 2025

    Shutdown Raises Concerns About IRS Reg Timing, 2026 Filing

    The federal government shutdown is likely to delay critical IRS guidance for retroactive tax provisions in this summer's budget bill and impair customer service at the agency as it drags on, causing headaches for taxpayers, tax observers say.

  • October 28, 2025

    US, Japan Sign Agreement On Key Minerals

    The U.S. and Japan agreed Tuesday to coordinate on securing and refining important minerals, while outlining a series of Japanese investments in U.S. industries, according to an announcement published by the White House.

  • October 28, 2025

    Norway Sees 30% Spike In Crypto Reporting To Tax Authority

    Norway saw a 30% spike in taxpayers who reported owning cryptocurrency last year, the country's tax authority said Tuesday, attributing the increase to its compliance efforts.

  • October 28, 2025

    UN Committee Seeks Feedback On Tax Treaty, Dispute Ideas

    Leaders of the intergovernmental negotiating committee on the United Nations framework convention on international tax cooperation are seeking comments on a template for the treaty and ideas for a protocol on dispute resolution.

  • October 27, 2025

    Cambodia Agrees To Cut Tariffs, Barriers In US Trade Deal

    Cambodia agreed to cut tariffs, refrain from imposing a digital services tax, remove nontariff trade barriers and accept U.S. regulatory standards in a trade agreement with the U.S. in exchange for tariff exemptions.

  • October 27, 2025

    US Unveils Trade Frameworks For Vietnam, Thailand Deals

    The U.S. issued new details on a framework trade deal it reached months ago with Vietnam and announced a new framework deal with Thailand, according to announcements made by the White House on Sunday.

  • October 27, 2025

    Malaysia Agrees To Toss Digital Tax In Trade Pact With US

    Malaysia agreed to stop imposing its digital services tax on U.S. companies, invest $70 billion stateside and lower trade barriers on American goods in a trade agreement with the U.S. in exchange for tariff exemptions.

  • October 27, 2025

    Australia Considering Updates To OECD Global Min. Tax

    Amendments clarifying rules on securitization entities are among updates proposed by the Australian Treasury for the country's legislation that implements the Pillar Two international minimum corporate tax agreement.

Expert Analysis

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

  • Attacks On Judicial Independence Tend To Manifest In 3 Ways

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    Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.

  • Section 899 Could Be A Costly Tax Shift For US Borrowers

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    Intended to deter foreign governments from applying unfair taxes to U.S. companies, the proposal adding new Section 899 to the Internal Revenue Code would more likely increase tax burdens on U.S. borrowers than non-U.S. lenders unless Congress limits its scope, says Michael Bolotin at Debevoise.

  • Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use

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    The recent revelation that a handful of questions from the controversial California bar exam administered in February were drafted using generative artificial intelligence demonstrates the continued importance of disclosure for attorneys who use AI tools, say attorneys at Troutman.

  • In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable

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    The U.S. District Court for the Eastern District of Virginia was again one of the fastest civil trial courts in the nation last year, and an interview with the court’s newest judge provides insights into why it continues to soar, says Robert Tata at Hunton.

  • How Attorneys Can Become Change Agents For Racial Equity

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    As the administration targets diversity, equity and inclusion efforts and law firms consider pulling back from their programs, lawyers who care about racial equity and justice can employ four strategies to create microspaces of justice, which can then be parlayed into drivers of transformational change, says Susan Sturm at Columbia Law School.

  • Adapting To Private Practice: From US Attorney To BigLaw

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    When I transitioned to private practice after government service — most recently as the U.S. attorney for the Eastern District of Virginia — I learned there are more similarities between the two jobs than many realize, with both disciplines requiring resourcefulness, zealous advocacy and foresight, says Zach Terwilliger at V&E.

  • The Ins And Outs Of Consensual Judicial References

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    As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.

  • The BigLaw Settlements Are About Risk, Not Profit

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    The nine Am Law 100 firms that settled with the Trump administration likely did so because of the personal risk faced by equity partners in today's billion‑dollar national practices, enabled by an ethics rule primed for modernization, says Adam Forest at Scale.

  • Customs Fraud Enforcement In The Age Of Tariffs

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    In the wake of the Trump administration’s new approach toward tariffs, two recent Justice Department developments demonstrate aggressive customs fraud enforcement, with the DOJ emphasizing competitive harm to American businesses, and signaling that investigations will likely involve both civil and criminal enforcement tools, say attorneys at Bernstein Litowitz and London & Naor.

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