International
-
April 08, 2026
Tax Court Limits Varian's Deemed Dividends Deduction
A deduction that California-based Varian Medical Systems was allowed for deemed dividends must be reduced by the amount of its corresponding foreign tax credit, the U.S. Tax Court held Wednesday.
-
April 08, 2026
Oil Giants Owed Far More Tax Abroad Than In US, Report Says
Major U.S. energy companies continued to owe far more taxes abroad than domestically last year, with Exxon Mobil and Chevron each incurring less than 10% of their total liabilities from the federal government, the Financial Accountability and Corporate Transparency Coalition said in a report.
-
April 08, 2026
Pryor Cashman Hires Tax Atty In NY From Curtis
Pryor Cashman LLP announced Tuesday that it has hired a former Curtis Mallet-Prevost Colt & Mosle LLP partner, touting her history advising businesses on complex tax matters across jurisdictions.
-
April 08, 2026
Jamaica Saw $7.7B In Transfer Pricing Reports, OECD Says
Jamaica's tax authority saw a major boost in disclosures of transfer pricing transactions since overhauling its legal framework a decade ago, with transactions worth €6.6 billion ($7.7 billion) disclosed in the 2022-2023 fiscal year, the OECD said Wednesday in a report.
-
April 08, 2026
Engineering Co. Owes £3M Contributions, UK Court Says
A Scotland-based engineering company is on the hook for £2.9 million ($3.9 million) in national insurance contributions, according to a U.K. appeals court, which held the company couldn't avoid contributions by moving employee contracts offshore.
-
April 08, 2026
1 Year Later, How Tariffs Have Crept Into Real Estate Contracts
In the year since President Donald Trump's Rose Garden announcement of sweeping worldwide tariffs last April, real estate and construction lawyers have wrestled with how duties or potential duties fit into clients' deals, and sources recently shared more than half a dozen contract examples from the past year with Law360 Real Estate Authority.
-
April 08, 2026
UK Gov't Expands Tax Relief For Startup Investment
The U.K.'s Labour government is expanding investment tax relief to unlock £100 million ($134.4 million) worth of funding for startups and early-stage businesses looking to grow, according to HM Treasury.
-
April 08, 2026
Swiss Implement Guidance On Minimum Tax Safe Harbors
Switzerland is implementing OECD guidance on the 15% global minimum tax with regards to several safe harbors, including an exemption for U.S. companies, and the treatment of deferred tax assets, according to the country's tax authority.
-
April 07, 2026
Rivera Kept $50M Venezuela Deal Quiet, Ex-Partner Says
The government's star witness took the stand Tuesday in the criminal case against former U.S. Rep. David Rivera of Florida, telling jurors that Rivera and others kept a $50 million consulting contract with a unit of Venezuela's state-owned oil company quiet because of concerns about how it would be perceived in Miami.
-
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.
Expert Analysis
-
AI-Generated Doc Ruling Guides Attys On Privilege Risks
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
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
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
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
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
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
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
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
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
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
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
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
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.