International

  • July 22, 2025

    Rising Star: Kirkland's Devin Heckman

    Devin Heckman of Kirkland & Ellis LLP has advised clients on the tax aspects of several multibillion-dollar acquisitions involving technology and healthcare companies, forging ongoing relationships and earning him a spot among the tax attorneys under age 40 honored by Law360 as Rising Stars.

  • July 22, 2025

    UK Releases Proposed Changes To 15% Min. Tax Legislation

    The U.K. released draft legislation aimed at recalibrating its laws on the 15% global minimum tax in a number of ways, including capturing more permanent establishments, excluding more deferred tax assets and adjusting intragroup accounting discrepancies.

  • July 22, 2025

    Irish Board Affirms Tax Bill Against Loss Scheme Participant

    The Irish Tax Appeals Commission closed out one of the remaining cases stemming from an investment fund, citing a court decision that found the participants used the syndicate to generate losses to reduce their taxable income.

  • July 22, 2025

    UK Anti-Tax Avoidance Rules Inconsistent, HMRC Told

    The British government should seek to simplify its anti-tax avoidance rules for income tax to eliminate inconsistencies and avoid double taxation of earnings, accounting firms and tax professionals told HM Revenue & Customs in a consultation.

  • July 22, 2025

    Golf Adviser Reaped $2M In Secret Commissions, Court Rules

    A former consultant to a U.K. golf retailer engaged in deceit, breach of trust and breach of fiduciary duty to reap over $2 million in secret commissions related to sales of golf equipment, a London court ruled Tuesday.

  • July 22, 2025

    OECD Updates Transfer Pricing Profiles For 12 Countries

    The OECD updated 12 countries' entries in its transfer pricing database Tuesday, showing that while none of these countries has adopted the simplified approach for addressing baseline marketing and distribution activities known as Amount B, many have reached a political agreement on the measure.

  • July 22, 2025

    US Expatriations Over 1,000 Again In 2nd Quarter

    While about 200 fewer people expatriated from the U.S. in the second quarter of 2025 compared with the first quarter, the number still totaled above 1,000, the Internal Revenue Service said Tuesday.

  • July 22, 2025

    Gov't Sets Out Plan To Include Pensions In Inheritance Tax

    The government has confirmed that it is pushing ahead with plans to apply inheritance tax to wealth transferred through pensions in a move that experts say marks a "seismic" change for the sector.

  • July 21, 2025

    Guinea Tells DC Circ. $22M Award Can't Be Enforced

    The Republic of Guinea has urged the D.C. Circuit not to revive a consulting company's bid to enforce a $22 million arbitration award, saying a lower court correctly found that it was unclear whether the country agreed to arbitrate the dispute in the first place.

  • July 21, 2025

    Tax-Lien Biz Atty Tells Jury He Didn't Seek To Dupe Lender

    Counsel for a former compliance lawyer accused of pilfering from a $20 million line of credit extended to his tax-lien investment firm told a Manhattan federal jury Monday that the defendant was "sloppy," but never intended fraud.

  • July 21, 2025

    Rising Star: Davis Polk's Aliza Slansky

    Aliza Slansky of Davis Polk & Wardwell LLP is lead counsel in Sycamore Partners' $23 billion acquisition of Walgreens Boots Alliance and advised Missouri tech company Emerson on a series of multibillion-dollar sales, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 21, 2025

    UK Co. Faces £1M Penalty For Failing To Report Tax Scheme

    HM Revenue & Customs was right to determine that a company had promoted a contractor loan tax scheme, a London tribunal ruled, finding the Manchester-based business liable for up to £1 million ($1.3 million) in penalties.

  • July 21, 2025

    Strict Construction Rules Could Gut Solar, Wind Credits

    The U.S. Treasury Department could severely weaken the availability of the solar and wind energy tax credits that were scaled back under Republicans' new budget law with upcoming guidance that may upend long-standing construction rules used to determine eligibility.

  • July 21, 2025

    Family Claims Bad Tax Advice Led To Costly HMRC Bills

    The trustees of family trusts accused a U.K. accounting firm of giving them negligent advice that led to unexpected inheritance taxes and penalties owed to HM Revenue & Customs, according to a claim filed in a London court.

  • July 21, 2025

    UK Launches Online Service Available For 35M Taxpayers

    HM Revenue & Customs launched an online Pay As You Earn portal Monday, available to 35 million U.K. taxpayers, that the British revenue agency said is intended to make it easier to check on tax information as part of HMRC's overall digital transformation.

  • July 21, 2025

    Paul Hastings Boosts Tax Team In NY With Ex-Kirkland Atty

    Paul Hastings LLP announced Monday that a former Kirkland & Ellis LLP attorney is bringing her tax practice to its New York office in a move the firm says will bolster its ability to guide clients through complex deals like mergers, acquisitions and private equity transactions.

  • July 18, 2025

    Law360 Names 2025's Top Attorneys Under 40

    Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age.

  • July 18, 2025

    Trade Legal Matters To Watch: Midyear Report

    Aggressive, sweeping tariff actions have defined the first six months of President Donald Trump's second term, altering the global trade environment in attempts to return manufacturing to the U.S. and reset trading deficits, but legal challenges to certain duties may obstruct Trump's long-term trade strategy in ongoing negotiations later this year.

  • July 18, 2025

    HMRC Urged To Broaden Reporting Of Uncertain Tax Positions

    HM Revenue & Customs may need to change its rules for when taxpayers must disclose uncertain tax positions they've taken to the tax authority, according to a report by a nonprofit research organization.

  • July 18, 2025

    IRS Offers Guidance On Use Of Transfer Pricing Exception

    Taxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday.

  • July 18, 2025

    Trump Asks Supreme Court To Decline Early Tariff Challenge

    President Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts.

  • July 18, 2025

    Western Union Says IRS Used Flawed Rule To Hike Income

    The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.

  • July 18, 2025

    Taxation With Representation: Wachtell, Slaughter And May

    In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.

  • July 18, 2025

    European Tax Policy To Watch In 2nd Half Of 2025

    The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months.

  • July 18, 2025

    EU To Make Foreign Traders Liable For VAT On Imports

    Foreign companies, rather than consumers, will become liable for value-added tax on imports to the European Union beginning July 2028 under a directive adopted Friday by the bloc's council of member states, according to a news release.

Expert Analysis

  • 5 Litigation Funding Trends To Note In 2025

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    Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.

  • Rethinking Litigation Risk And What It Really Means To Win

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    Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.

  • Small Biz Caught In Corporate Transparency Act Crossfire

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    Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.

  • No, Litigation Funders Are Not 'Fleeing' The District Of Del.

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    A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.

  • 5 E-Discovery Predictions For 2025 And Beyond

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    In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.

  • What's Ahead As Transparency Act Comes To A Crossroads

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    Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.

  • 7 Ways 2nd Trump Administration May Affect Partner Hiring

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    President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.

  • E-Discovery Quarterly: Rulings On Custodian Selection

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    Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.

  • Exploring Venue Strategy For Trump-Era Regulatory Litigation

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    Litigation will likely play a prominent role in shaping policy outcomes during the second Trump administration, and stakeholders have several tools at their disposal to steer regulatory litigation toward more favorable venues, say attorneys at Covington.

  • An Associate's Guide To Career Development In 2025

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    As the new year begins, associates at all levels should consider establishing career metrics, fostering key relationships and employing other specific strategies to help move through the complexities of the legal profession with confidence and emerge as trailblazers, say EJ Stern and Amanda George at Fractional Law Firm.

  • Making The Pitch To Grow Your Company's Legal Team

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    In a compressed economy, convincing the C-suite to invest in additional legal talent can be a herculean task, but a convincing pitch — supported by metrics and cost analyses — may help in-house counsel justify the growth of their team, say Elizabeth Smith and Roger Garceau at Major Lindsey.

  • Tax Court Should Update Framework For Defining Insurance

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    ​​​​​​​The U.S. Tax Court's unnecessary determination in Royalty Management Insurance v. Commissioner that a fraudulent transaction did not contain the hallmarks of a legitimate insurance transaction applies an outdated analysis that threatens the captive insurance sector and illustrates the need for a more modern framework to define true insurance, says Matthew Queen at the Queen Firm.

  • When US Privilege Law Applies To Docs Made Outside The US

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    As globalization manifests itself in disputes over foreign-created documents, a California federal court’s recent trademark decision illustrates nuances of both U.S. privilege frameworks and foreign evidentiary protections that attorneys must increasingly bear in mind, say attorneys at Hunton.

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