International

  • October 16, 2026

    Eaton To Defend Prices Paid For Breaker Products At Trial 2

    Ohio-based Eaton Corp. is preparing to defend the prices it paid during 2011 to 2013 for electrical breakers and other products from manufacturing affiliates in Puerto Rico and the Dominican Republic when its second U.S. Tax Court trial begins Nov. 2.

  • October 16, 2026

    UK Gov't Expected To Raise Bank Taxes In Autumn Budget

    The U.K.'s Labour government is preparing to raise taxes on banks in the autumn budget, according to a newspaper report, including a possible hike to the bank levy.

  • October 16, 2026

    UK Appeals Court Bars Loan Loss Relief After Share Swap

    A former U.K. business owner cannot get a tax deduction on the £2.2 million ($2.9 million) he lent his sports bookstore before it shuttered, a London appeals court ruled Friday, holding he had waived the store's debt in exchange for shares.

  • October 16, 2026

    UK Gov't Rejects Tax Break For Hiring Workers Under 25

    The U.K. government ruled out plans to grant companies a payroll tax break for hiring workers between ages 21 and 25 in a statement to Parliament.

  • October 16, 2026

    EU Parliament Draft Scraps Pillar 2 Exemption In Tax Info Bill

    A report from a member of the European Parliament would remove an exemption for Pillar Two companies in a tax data bill that is in the European Union's legislative pipeline.

  • October 15, 2026

    Australia Seeks Ability For Tax Office To Tackle Preparer Fraud

    Australian tax preparers who misuse client information to defraud the government could be forced to pay related tax debts, rather than watch their clients go through the payment process, according to a proposal from the Australian Treasury.

  • October 15, 2026

    EU Court OKs Looking Past Initial Payment In Dividend Case

    The European Union's top court ruled Thursday that authorities can deny a dividend withholding tax exemption on the basis of tax abuse even when the parent firm receiving the payments is a genuine company that has the right to use those dividends, rather than a shell firm.

  • October 15, 2026

    German Tax Deferral Violates EU Rules, CJEU Adviser Says

    Germany's provision of a capital gains tax deferral only to companies with a German permanent establishment infringes on European Union rules concerning the free movement of capital, an adviser to the Court of Justice of the EU said Thursday.

  • October 15, 2026

    Co. Can't Use HMRC Call To Defeat Tax On COVID Payments

    A company cannot argue newly on appeal that HM Revenue & Customs was barred from assessing income tax on overpayments of government assistance during the height of the COVID-19 pandemic because an officer told the company its tax affairs didn't require further action, the Upper Tribunal has found.

  • October 15, 2026

    IRS Finalizes Liability Regs In Corporate Group Transfers

    The Internal Revenue Service finalized regulations Thursday clarifying that a corporate subsidiary's tax basis in stock received in an intracompany transfer will exclude certain liabilities assumed by the transferee subsidiary, affecting affiliated groups of companies that file one income tax return together.

  • October 15, 2026

    Australian Parliament Weighs Crypto Tax Transparency Rules

    The Australian Treasury submitted draft legislation to Parliament on Thursday that would implement international and domestic digital asset transparency frameworks to help tax officials collect and share cryptocurrency data.

  • October 15, 2026

    HMRC Probes Of Soccer Clubs Raise £87M In Tax

    The U.K.'s tax authority recovered £87 million ($115 million) in extra tax from inquiries into soccer clubs in fiscal year 2025-26, according to data published Thursday.

  • October 15, 2026

    Tribunal OKs Contrasting Approach To Deny VAT Deductions

    The First-tier Tribunal didn't err by allowing HMRC to use a fraud-based argument to deny a waste management company £1.8 million ($2.4 million) in value-added tax deductions alongside an alternative argument that no taxable supply existed, which would undercut the main case, the Upper Tribunal said.

  • October 14, 2026

    Trustee Asks 1st Circ. To Nix Shuttered Bank Owner's Claims

    A Puerto Rico federal court properly dismissed claims against a trustee appointed to administer the receivership of a shuttered online bank suspected of facilitating tax evasion and money laundering, he told the First Circuit, saying he's entitled to 11th Amendment immunity because he was sued in his official capacity.

  • October 14, 2026

    Full Fed. Circ. Won't Review Brick Duty Definition Holding

    The Federal Circuit said Wednesday that it won't reconsider its determination that the U.S. Court of International Trade properly found duty orders on certain heat-resistant bricks lack specific chemical makeup parameters, despite a claim the ruling ran afoul of precedent and will cause "devastating harm."

  • October 14, 2026

    Canadian Mining Co., Mexico Move To Settle $1.3B Tax Feud

    A Canadian mining company reached an agreement in principle with Mexico to settle a dispute over the validity of transfer pricing arrangements for offshore silver dealings by the company's subsidiary that have led to nearly $1.3 billion in assessments of taxes, penalties and interest.

  • October 14, 2026

    Germany Floats Tax On Sugary Drinks To Curb Health Costs

    Germany wants to tax sugary drinks starting next year in an effort to cut sugar consumption and reduce public healthcare costs, according to a proposal approved Wednesday by the Federal Cabinet.

  • October 14, 2026

    Double Tax Fears In UN Talks Are Overblown, Economists Say

    Wealthy countries are invoking the risk of double taxation to defend existing international tax rules that let multinational corporations pay little or nothing, a group of economists said Wednesday in urging good faith negotiations at an upcoming United Nations conference.  

  • October 14, 2026

    HMRC Details Soccer Tax Work Amid Man City Findings

    The U.K. tax authority outlined its soccer compliance work to a parliamentary committee in a letter released Wednesday, but it remained silent on the findings of an independent soccer commission that Manchester City Football Club used "sham" contracts to inflate its income.

  • October 14, 2026

    Raising Capital Gains Tax A Risky Move, Ex-Labour Aide Says

    The U.K.'s Labour government should be wary of raising capital gains tax rates in its autumn budget given the risks for businesses and investment, a former adviser to Prime Minister Andy Burnham told a parliamentary committee Wednesday.

  • October 14, 2026

    Draft EU Tax Data Bill Leaves More Room For Rule Overlap

    A new draft of a European Union bill on tax data exchanges seen Wednesday by Law360 removes a previously proposed ban on member states introducing or maintaining domestic data obligations that substantially duplicate the new EU requirements.

  • October 14, 2026

    EU Top Court Poised To Clarify Cross-Border Tax Rules

    The European Union's highest court is set to issue a ruling Thursday that's expected to provide clarity on whether authorities can deny a cross-border withholding tax exemption on the basis of tax abuse even when dividends are sent to a genuine parent company rather than a shell company.

  • October 13, 2026

    Expat To Push 11th Circ. For Trial Over $20M FBAR Fines

    An expatriate U.S.-German citizen is appealing a Florida federal court's rejection of his attempt to set aside an approximately $20 million judgment against him for failing to file reports of foreign bank accounts, an outcome he said violated his rights to a jury trial.

  • October 13, 2026

    Trade Court Backs Commerce On Solar Module Duty Scope

    The U.S. Department of Commerce properly determined an importer's solar-powered charging modules should be subject to countervailing and antidumping duties on Chinese solar cell products, according to an opinion published Tuesday by the U.S. Court of International Trade.

  • October 13, 2026

    Nelson Mullins Adds Ex-Berger Singerman Tax And Estate Pro

    Nelson Mullins Riley & Scarborough LLP has hired a new partner from Berger Singerman to bolster its international tax, estate planning and private wealth capabilities in Miami.

Expert Analysis

  • Calculating Damages In IEEPA Tariff Refund Litigation

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    To calculate damages in the spate of refund litigation triggered by the U.S. Supreme Court's recent decision invalidating tariffs collected under the International Emergency Economic Powers Act, the central question will be how to determine where in the supply chain their economic burden ultimately came to rest, say analysts at Charles River Associates.

  • Alpine Skiing Makes Me A Better Lawyer

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    Skiing has shaped habits I rely on daily as an attorney — focus, resilience and the ability to remain steady when circumstances shift rapidly — and influences the way I approach legal strategy, client counseling and teamwork, says Isaku Begert at Marshall Gerstein.

  • What A Court Doc Audit Reveals About Erroneous Filings

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    My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.

  • Getting The Most Out Of Learning And Development Programs

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    Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.

  • AI Presents A Make-Or-Break Moment For Outside Counsel

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    The rapid adoption of artificial intelligence by corporate legal departments is forcing a long-overdue reset of the relationship between inside and outside counsel, and introducing a significant opportunity to shed frustrating inefficiencies and strengthen collaboration for firms willing to embrace the shift, says Intel Chief Legal Officer April Miller Boise.

  • 8 Tariff Refund Questions For Restructuring Professionals

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    For restructuring and turnaround professionals, seeking refunds following the U.S. Supreme Court's recent decision invalidating tariffs imposed under the International Emergency Economic Powers Act raises several questions about how to capture legitimate recoveries while protecting an enterprise from the consequences of its own history, says Jonny Frank and Laura Greenman at StoneTurn, and Andrew Popescu at Province.

  • 5 Tips For Navigating Your Firm's All-Attorney Summit

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    Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.

  • The Benefits Of Choosing A Niche Practice In The AI Age

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    As artificial intelligence becomes increasingly accessible, lawyers with a niche practice may stand out as clients seek specialized judgment that automation cannot replicate, but it is important to choose a niche that is durable, engaging and a good personal fit, says Daniel Borneman at Lowenstein Sandler.

  • Tax Court Ruling Signals Cross-Border Loan Scrutiny

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    The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.

  • How Banks Can Apply FinCEN Beneficial Ownership Relief

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    A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.

  • Aligning Microsoft Tools With NYC Bar AI Recording Guidance

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    The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.

  • 5 Different AI Systems Raise Distinct Privilege Issues

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    A New York federal court’s recent U.S. v. Heppner decision, holding that a defendant’s use of Claude was not privileged, only addressed one narrow artificial intelligence system, but lawyers must recognize that the spectrum of AI tools raises different confidentiality and privilege questions, says Heidi Nadel at HP.

  • AI-Assisted Arbitration Needs Safeguards To Ensure Fairness

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    As tribunals and arbitral institutions increasingly use artificial intelligence tools in their decision-making processes, ​​​​​​​clear disclosure standards and procedural safeguards are necessary to ensure that efficiency gains do not erode the fairness principles on which arbitration depends, says Alexander Lima at Wesco International.

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