International

  • 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.

  • May 08, 2026

    Disbarred Atty Can't Escape Tax Evasion Case, 2nd Circ. Says

    A disbarred English attorney who assisted the heirs of an American businessman in evading taxation on their inheritance cannot use an "extraordinary" post-conviction remedy to overturn part of the verdict and a $4 million restitution bill, the Second Circuit ruled Friday.

  • May 08, 2026

    Nike Customers Join Tariff Refund Class Action Trend

    A group of Nike customers on Friday joined the growing number of proposed class actions looking to secure legal rights to refunds of costs tied to President Donald Trump's now-invalidated global tariff regime, saying they were the ones who actually bore the costs.

  • May 08, 2026

    Why Trump's 2nd Global Tariff May Fare Better On Appeal

    President Donald Trump's administration on Friday appealed the U.S. Court of International Trade's ruling deeming his temporary global tariff unlawful to the Federal Circuit, where judges may view the executive action with more deference than the measures it immediately replaced.

  • May 08, 2026

    Clarity Sought On Energy Tax Credits And Foreign Debt

    The IRS should issue more guidance on what kind of debt arrangements can limit a development project's access to clean energy tax credits under new prohibited foreign entity requirements as uncertainty over financial liability and ownership becomes a major market concern, practitioners said Friday.

  • May 08, 2026

    US, Romania Have Wrapped Up Tax Treaty Talks, Official Says

    The U.S. and Romania recently completed negotiations on their double-tax treaty and are conducting reviews of the changes, an official with the U.S. Department of the Treasury said Friday.

  • May 08, 2026

    Former Exec Didn't Prove Resignation, Canada Tax Court Says

    A businessman didn't exercise due diligence and failed to prove he stepped down from a company position, leaving him liable for unremitted goods and services taxes, a Toronto court ruled.

  • May 08, 2026

    Taxation With Representation: Corrs, Kirkland, Linklaters

    In this week's Taxation With Representation, gold companies Regis Resources and Vault Minerals combine, Long Lake Management acquires American Express Global Business Travel and Vodafone buys out CK Hutchison Holdings to become the sole owner of their telecommunications joint venture.

  • May 08, 2026

    UK Dentist Wins Appeal To Overturn £225K In Tax Penalties

    A London tribunal canceled tax penalties totaling nearly £225,000 ($306,000) that Britain's tax authority imposed on a dentist who unwittingly joined a fraudulent tax scheme on the advice of his accountant.

  • May 08, 2026

    Liberty Global Easy Case For 10th Circ., IRS Atty Says

    The Internal Revenue Service's recent win against telecommunications giant Liberty Global, whose complex transactions were held to be a tax shelter lacking economic substance, was an "easy affirmance" for the Tenth Circuit and an easy decision for the district court, an agency official said Friday.

  • May 07, 2026

    Trump's Temporary Global Tariffs Illegal, Trade Court Rules

    President Donald Trump's temporary global 10% tariffs are unlawful because the narrow set of economic conditions required for the measure to be imposed were not met, the U.S. Court of International Trade said Thursday in a divided opinion.

  • May 07, 2026

    Wyden Probes Wall Street Firms For Tariff Refund Stakes' Info

    The top Democratic lawmakers on the Senate Finance Committee sent letters to major Wall Street firms Thursday about their activity in buying the rights to importers' tariff refund interests at a discount following the U.S. Supreme Court's decision in February striking down President Donald Trump's emergency tariff regime. 

  • May 07, 2026

    Carbon Tax Revenues Fall Far Short Of Potential, Report Says

    Carbon taxes worldwide raised less than a third of the revenue they could have recently, weighed down by exemptions, reduced rates, compliance gaps and other carbon pricing systems carving out the tax base, the Tax Foundation said Thursday in a report.

  • May 07, 2026

    Stinson Real Estate Finance Atty Joins Reed Smith In DC

    Reed Smith LLP has hired a Stinson LLP lawyer who focuses her practice on real estate finance matters, renewable energy tax credit and new market tax credit issues, the firm has announced.

  • May 07, 2026

    Italian Man Arrested Amid Probe Into Large-Scale VAT Fraud

    Italian authorities have arrested a businessman suspected of laundering the proceeds of a multimillion-euro value-added tax fraud, the European Public Prosecutor's Office said.

  • May 07, 2026

    Iran War Risks £8B Annual Tax Hit To UK, Report Warns

    The Iran war could cost the U.K. government up to £8 billion ($10.9 billion) a year through lost tax revenue and higher debt interest payments, a progressive think tank warned Thursday.

  • May 07, 2026

    Iran War Sees Germany Downgrade Tax Revenue Expectations

    Germany downgraded its tax revenue forecasts Thursday at all levels of government for each year through 2030 due to the Iran war.

Expert Analysis

  • Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling

    Author Photo

    The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.

  • What 2 Profs Noticed As Transactional Law Students Used AI

    Author Photo

    After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.

  • BigLaw Settlements Should Not Spur Ethics Deregulation

    Author Photo

    A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.

  • 5 Ways Lawyers Can Earn Back The Public's Trust

    Author Photo

    Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.

  • Legal Jeopardy Looms Over Trump's Trade Negotiation Plans

    Author Photo

    Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.

  • What US-India Trade Deal Will Mean For Indian Pharma

    Author Photo

    Complicated by newly imposed tariffs from the U.S., the outcome of the U.S.-India trade talks is poised to reshape not just trade policy, but also the strategic alignment of the two countries' pharmaceutical ecosystems, says Jashaswi Ghosh at Holon Law Partners.

  • Bar Exam Reform Must Expand Beyond A Single Updated Test

    Author Photo

    Recently released information about the National Conference of Bar Examiners’ new NextGen Uniform Bar Exam highlights why a single test is not ideal for measuring newly licensed lawyers’ competency, demonstrating the need for collaborative development, implementation and reform processes, says Gregory Bordelon at Suffolk University.

  • A Simple Way Courts Can Help Attys Avoid AI Hallucinations

    Author Photo

    As attorneys increasingly rely on generative artificial intelligence for legal research, courts should consider expanding online quality control programs to flag potential hallucinations — permitting counsel to correct mistakes and sparing judges the burden of imposing sanctions, say attorneys at Lankler Siffert & Wohl and Connors.

  • The Legal Education Status Quo Is No Longer Tenable

    Author Photo

    As underscored by the fallout from California’s February bar exam, legal education and licensure are tethered to outdated systems, and the industry must implement several key reforms to remain relevant and responsive to 21st century legal needs, says Matthew Nehmer at The Colleges of Law.

  • 6 Questions We Should Ask About The Trump Trade Deals

    Author Photo

    Whenever the text becomes available, certain questions will help determine whether the Trump administration’s trade deals with U.S. trading partners have been crafted to form durable economic relationships, or ephemeral ties likely to break upon interpretive disagreement or a change in political will, says Ted Posner at Baker Botts.

  • E-Discovery Quarterly: Rulings On Relevance Redactions

    Author Photo

    In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.

  • Section 1983 Has Promise After End Of Nationwide Injunctions

    Author Photo

    After the U.S. Supreme Court recently struck down the practice of nationwide injunctions in Trump v. Casa, Section 1983 civil rights suits can provide a better pathway to hold the government accountable — but this will require reforms to qualified immunity, says Marc Levin at the Council on Criminal Justice.

  • Playing Soccer Makes Me A Better Lawyer

    Author Photo

    Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.

Can't find the article you're looking for? Click here to search the Tax Authority International archive.