International

  • May 13, 2026

    Accendra Pays $19M To Settle IRS Transfer Pricing Matter

    Accendra Health Inc. paid $19 million to the Internal Revenue Service to conclude tax matters related to international transfer pricing activity between 2015 and 2018, according to a recent earnings call with investors.

  • May 13, 2026

    Trump 1st-Term Tariff Hikes On China Legal, Feds Tell Justices

    President Donald Trump's first administration was well within its legal authority to increase tariffs on Chinese goods under a law utilized to address unfair trading practices, and the U.S. Supreme Court doesn't need to consider a challenge to those measures, the government told the justices.

  • May 13, 2026

    Tax Court Won't Rethink Nix Of Russian Scientist's Exemption

    The U.S. Tax Court won't rethink its decision that the U.S. Department of Energy's payments to a Russian scientist for his subatomic particle research in Virginia don't fall under a tax exemption for grants in the U.S.-Russia tax treaty.

  • May 13, 2026

    GM Unit's Pricing Shift Doesn't Affect VAT, EU High Court Says

    The Portuguese government should not have increased the value-added tax bill for automaker Stellantis, the European Union's top court ruled Wednesday, holding that intercompany transactions between the former General Motors Co. subsidiary and European manufacturers fell outside the VAT's scope.  

  • May 13, 2026

    HMRC Warns Against New Fraud Trend

    A growing number of taxpayers are falling for scammers promoting bills of exchange as a means of paying off a tax liability, Britain's tax authority warned Wednesday.

  • May 13, 2026

    Suspect Arrested In €18M Electronics VAT Fraud Scheme

    European prosecutors said Wednesday that German authorities arrested one suspect and carried out a series of raids in an investigation into an alleged €18 million ($21 million) value-added tax carousel fraud involving the cross-border sale of small electronics.

  • May 13, 2026

    Hungary Issues Guidance On Global Minimum Tax Return Info

    Hungary issued guidance Wednesday for companies, covering how to file information returns for the 15% global minimum tax.

  • May 12, 2026

    9th Circ. Orders New Tax Fraud Trial Over Juror's Racial Bias

    An Idaho federal court wrongly denied a man of Mexican descent a new trial after discovering a juror had made racially biased comments about people of Mexican ethnicity during deliberations on whether to convict him of preparing false tax returns, a split Ninth Circuit panel said Tuesday.

  • May 12, 2026

    Over 8 Million Imports In Line For Over $35B In Tariff Refunds

    Over 8.3 million imports are pending tariff refunds after clearing the final system processes developed by Customs and Border Protection, accounting for almost $35.5 billion in duty refunds with interest, according to the latest declaration filed Tuesday by an agency official in the U.S. Court of International Trade.

  • May 12, 2026

    Fed. Circ. Pauses Trade Court Ruling Blocking Trump Tariffs

    The Federal Circuit halted a permanent injunction issued by the U.S. Court of International Trade that was scheduled to take effect on Tuesday, which would have stopped the collection of duties under President Donald Trump's temporary global tariff from two businesses and the state of Washington.

  • May 12, 2026

    Shell Wins Australia Tax Fight Over $71.6M In Added Taxes

    The Australian Taxation Office wrongly assessed AU$98.9 million ($71.6 million) in additional taxes to a Shell plc subsidiary by denying its entitlement to add a premium to its cost basis for a deemed acquisition of shares, the Federal Court of Australia said.

  • May 12, 2026

    Australia Aims to Curb Property Loss Tax Deductions

    The Australian government plans to implement measures aimed at limiting tax deductions in situations where interest expenses tied to rental properties exceed related income, which will raise 3.6 billion Australian dollars ($2.6 billion) over five years, according to a budget released Tuesday.

  • May 12, 2026

    Farmers Can't Challenge UK Inheritance Tax Relief Cut Plans

    Two Cambridgeshire farmers and a campaign group can't challenge the U.K. government's plans to slash inheritance tax relief for farms on the grounds that there should have been a public consultation before the proposals were announced, a London court ruled Tuesday.

  • May 12, 2026

    EU Readies Legal Action Over Weak Tax Reporting Penalties

    The European Union's executive branch may take member countries to court for failing to impose adequately high penalties on those that breach the bloc's rules on tax information sharing, an EU official said Tuesday.

  • May 12, 2026

    Gov't Clarifies Inheritance Tax Rules On Pension Wealth

    The government has issued a statement clarifying how it wants pension wealth to be brought into the scope of inheritance tax next year.

  • May 11, 2026

    Trump Asks Federal Circuit To Pause Trade Court Tariff Ruling

    President Donald Trump on Monday asked the Federal Circuit to block the U.S. Court of International Trade's order last week deeming his temporary global 10% tariffs unlawful, arguing the trade court misinterpreted the legislative history of the Trade Act.

  • May 11, 2026

    APA Results Should Make Sense Annually, IRS Official Says

    Taxpayers seeking advance pricing agreements with the Internal Revenue Service will now be expected to have the results of an agreed-upon transfer pricing method comply with the method on an annual basis rather than only over the multiple years covered by the APA, an IRS official said Monday.

  • May 11, 2026

    Amgen Late To Raise Double-Taxation Claim, Tax Court Told

    Biotechnology giant Amgen is making a "futile" attempt to raise a purported double-taxation issue for tax years 2016 through 2018 in a pair of transfer pricing cases before the U.S. Tax Court, the federal government said, arguing the disputed years fall outside the court's jurisdiction.

  • May 11, 2026

    Australia Preparing Decisions On Capital Gains Tax Issues

    Australia is preparing determinations and guidance on five issues related to capital gains taxation, including when anti-avoidance laws may be applied to multiple deferrals of liabilities and how the tax applies when a cryptocurrency is pegged to another cryptocurrency, the Australian Taxation Office said Monday.

  • May 11, 2026

    1 In 3 Large UK Companies Faced HMRC VAT Probe

    Britain's tax authority investigated one in three large companies on value-added tax matters in financial year 2024-25 as part of efforts to crack down on noncompliance, according to official data.

  • May 11, 2026

    McKesson Says Loper Bright Sinks IRS Cost-Sharing Rules

    Pharmaceutical giant McKesson asked a Texas federal court to strike down cost-sharing transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. Supreme Court's Loper Bright ruling forecloses previous deference to rule writers.

  • May 09, 2026

    IRS Scrutiny Of Immigrant Employment Tax Fraud To Continue

    Scrutinizing businesses with potential employment tax fraud issues related to undocumented immigrants will remain among the Internal Revenue Service Criminal Investigation division's top priorities, a senior division executive said Saturday.

  • May 09, 2026

    Spinoff Letter Rulings Valuable For IRS Too, Agency Atty Says

    The Internal Revenue Service has resumed issuing letter rulings on significant issues in tax-free spinoffs, and an IRS attorney on Saturday encouraged companies to use the program, as it provides the agency with valuable information on the transactions.

  • May 09, 2026

    Admin Cost Of Tax Presence Shouldn't Top Profit, Pros Say

    The administrative costs for a company or individual triggering a taxable presence, or permanent establishment, in a jurisdiction shouldn't exceed the profit allocable to the entity, transfer pricing specialists said Friday.

  • May 08, 2026

    AI's Use In Transfer Pricing Still Evolving, Tax Pros Say

    The use of artificial intelligence in transfer pricing is expected to ease compliance and reduce costs for clients, but multiple questions remain about the technology's potential and how it should be applied, a panel of tax experts said Friday.

Expert Analysis

  • Law School's Missed Lessons: Communicating With Clients

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    Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

  • Navigating Antitrust Risks When Responding To Tariffs

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    Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.

  • Key Points From HMRC's Tax Reform Proposals

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    Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • What To Note As UK Adopts OECD Crypto Disclosure Rules

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    With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • 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.

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