International

  • June 02, 2025

    Montana Tribal Tariff Dispute Will Stay In US Trade Court

    A Montana federal judge won't reconsider an order to transfer a challenge to President Donald Trump's Canada tariff orders by members of the Blackfeet Nation to the U.S. Court of International Trade, saying the CIT has historical jurisdiction over claims by tribal members on import and duty-related actions.

  • June 02, 2025

    White House Asks DC Circ. To Halt Tariff Injunction

    The White House on Monday asked the D.C. Circuit to hit pause on a lower court ruling that found President Donald Trump's tariffs unlawful, arguing the "legally indefensible preliminary injunction" would impede sensitive trade negotiations if left unchecked.

  • June 02, 2025

    IRS Issues Interim Regs To Simplify Corp. AMT Determination

    The Internal Revenue Service released temporary regulations Monday that offered a simplified method for large companies seeking to determine whether the 15% corporate alternative minimum tax applies to them, as well as penalty relief for those that underpaid the levy this year.

  • June 02, 2025

    Bahamas Looks To Update Corp. Minimum Tax Rules

    The Bahamas is looking for input on changes to its adoption of the OECD's minimum corporate income tax on large multinationals in order to better align it with updated standards, among other goals, the country said.

  • June 02, 2025

    Finland Plans Further Tweaks To Soft Drink Tax After EU Input

    While the European Commission broadly found that Finland's plan to alter its sugary drink tax to create different tiers based on sugar content didn't violate state aid rules, it called for some tweaks that the country will pursue, Finland's Finance Ministry said Monday.

  • June 02, 2025

    Halliburton Wants IRS To Release Docs In $35M Tax Dispute

    The Internal Revenue Service should be ordered to comply with Halliburton's discovery requests in a dispute over a $35 million deduction for payments the company said it made to a foreign government to protect its employees from harassment, the company told a Texas federal court.

  • June 02, 2025

    GOP Budget Adds Punitive Twist To Talks On Digital Taxes

    The House-passed budget's punitive tax hikes on companies and people from countries with digital services taxes is poised to complicate trade negotiations aimed at removing DSTs and to weaken foreign investment in the U.S., fiscal experts told Law360.

  • June 02, 2025

    Remote Workers Take German Tax Case To EU's Top Court

    The European Court of Justice said Monday it will hear the case of two taxpayers against a German regional tax authority over whether Swiss residents working remotely are taxable in Germany.

  • June 02, 2025

    CJEU Set To Hear SocGen's Case In Swedish Tax Dispute

    The Court of Justice of the European Union said Monday that it will hear the case of French banking giant Société Générale SA against the Swedish tax authority over the taxation of nonresident companies under the European treaty.

  • June 02, 2025

    OECD Releases Consolidated Text Of Data-Swap Guidance

    The Organization for Economic Cooperation and Development published consolidated text of a global reporting standard Monday to help tax administrations exchange financial information about individuals who may be trying to hide money from their tax authorities at home.

  • June 02, 2025

    IRS To Hold Hearing On Sourcing Cloud Transaction Income

    The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.

  • May 30, 2025

    US-China Trade Talks Could Resume After Stall Over Minerals

    Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.

  • May 30, 2025

    Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight

    An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.

  • May 30, 2025

    HMRC Correctly Handled Land Tax Dodge, UK Court Says

    HM Revenue & Customs followed the correct procedures to collect taxes on six individuals who attempted to dodge the U.K.'s land tax by transacting with a special purpose vehicle in Guernsey, the Upper Tribunal ruled.

  • May 30, 2025

    Isle Of Man Agrees To Work With UK Against Tax Avoidance

    Isle of Man authorities reached an agreement with the U.K. government to work together in a crackdown on promoters of tax avoidance schemes, according to a joint statement.

  • May 30, 2025

    UK Midsize Biz Owners Wary Of Risk Exposure, Report Says

    Owners and operators of midsize U.K. businesses are just as wary of risk exposure in personal taxes as they are in business taxes except under certain circumstances, according to a report commissioned by HM Revenue & Customs.

  • May 30, 2025

    Taxation With Representation: Kirkland, Cravath, Latham

    In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.

  • May 29, 2025

    DC Court Blocks Trump's Tariffs As Overreach Of Power

    The International Emergency Economic Powers Act does not empower the president to impose tariffs, the D.C. federal district court said Thursday, ruling that President Donald Trump's global levies are unlawful and barring his administration from enforcing them on two toymakers who challenged the policies.

  • May 29, 2025

    Fed. Circ. Revives Trump Tariffs As It Weighs Appeal

    The Federal Circuit temporarily reinstated President Donald Trump's global tariffs Thursday, a day after the U.S. Court of International Trade held that an emergency law did not give the president "unbounded authority" to impose the measures.

  • May 29, 2025

    Australia Outlines Compliance For Thin Capitalization Test

    The Australian Taxation Office is looking for feedback on draft compliance guidance for corporations looking to use one of its new thin capitalization tests as they relate to cross-border financing arrangements, it said Thursday.

  • May 29, 2025

    £2.4B Employment Tax Credit Has Limited Value, Report Says

    A U.K. employment tax credit worth around £2.4 billion ($3.2 billion) a year in payroll tax relief for businesses has limited value, according to a report commissioned by HM Revenue & Customs, with the smallest businesses reaping the most benefit.

  • May 29, 2025

    Biz Group Calls On EU To Resolve Pillar 2 Dispute With US

    The European Union should work quickly to resolve problems with the Pillar Two global minimum corporate tax and its interaction with the U.S. tax system, the American Chamber of Commerce for the EU said.

  • May 29, 2025

    IRS Annual Gross Collections Top $5 Trillion For First Time

    The Internal Revenue Service collected $5.1 trillion in gross revenue in fiscal year 2024, a 9% increase over last year's $4.7 trillion total, marking the first time the tax haul has been above $5 trillion, the agency said Thursday.

  • May 29, 2025

    US Tariffs Spark Profit Warnings For UK Pension Sponsors

    British businesses might seek to tap into pension surpluses because of ongoing financial losses caused by U.S. tariffs, a professional services firm has warned.

  • May 28, 2025

    International Trade Court Strikes Down Trump's Tariffs

    The International Emergency Economic Powers Act does not give the president the "unbounded authority" to impose tariffs on goods from nearly every country in the world, the U.S. Court of International Trade ruled Wednesday, handing a win to small businesses and states challenging some of President Donald Trump's steep tariffs.

Expert Analysis

  • 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.

  • Impact Of Corporate Transparency Act Ambiguity On Banks

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    Even though banks generally needn't file beneficial ownership information reports, financial institutions must continue to monitor the status of the Corporate Transparency Act and understand its requirements in case the nationwide injunction that was issued against the CTA earlier this month is overturned, say attorneys at Armstrong Teasdale.

  • 6 Changes I Would Make If I Ran A Law School

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    Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.

  • Firms Still Have The Edge In Lateral Hiring, But Buyer Beware

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    Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.

  • Think Like A Lawyer: 1 Type Of Case Complexity Stands Out

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    In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.

  • Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity

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    Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.

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