International

  • April 17, 2026

    3 Key Questions On Trump's Pharma Tariffs

    President Donald Trump recently announced 100% tariffs on certain imported pharmaceutical products, with opportunities for drug companies to lower their tariff rates to zero, but questions remain about the requirements for preferential treatment and abilities to administer the regime. Here, Law360 examines three open questions surrounding pharmaceutical tariffs' implementation.

  • April 17, 2026

    Tax Arbitrage Guidance Due This Year, OECD Official Says

    The Organization for Economic Cooperation and Development hopes to publish guidance this year on tax arbitrage that could be relevant to the application of what's known as the Pillar Two side-by-side package, created to recognize the U.S. minimum tax system, an OECD official said Friday.

  • April 17, 2026

    Brexit Backer Owes Inheritance Tax On Donations, Court Says

    A former hedge fund manager who donated about £750,000 ($1 million) to political groups that mostly advocated for Brexit isn't exempt from about £100,000 of inheritance tax on his donations, the First-tier Tribunal said in a judgment.

  • April 17, 2026

    Taxation With Representation: Skadden, Stikeman Elliott

    In this week's Taxation With Representation, Amazon.com Inc. buys satellite communications company Globalstar Inc., waste management company GFL Environmental Inc. acquires Secure Waste Infrastructure Corp., and Standard Life PLC buys the British subsidiary of Dutch insurer Aegon.

  • April 17, 2026

    Furniture Cos.' $19M Captive Insurance Scam Suit Resumed

    A Maryland federal court has resumed a lawsuit accusing a D.C. corporate tax attorney and his former law firm of a $19 million captive insurance scam following notification that the bankruptcy proceedings of the attorney and the firm have concluded.

  • April 17, 2026

    Taxing Digital Economy Gaining More Traction, OECD says

    An official from the Organization for Economic Cooperation and Development said Friday that the Paris-based group is engaging in constructive dialogue on the taxation of the digital economy as interest in the subject grows.

  • April 16, 2026

    Senate Bill Seeks To End Carried Interest Tax Break

    Fund managers would face annual taxation of carried interest based on imputed compensation, instead of primarily enjoying long-term capital gains rates, under a bill introduced Thursday by Senate Finance Committee ranking member Ron Wyden, the latest in a decades-long drive to end the tax break.

  • April 16, 2026

    UK Travel Co. Can Challenge VAT Credit Adjustment

    A travel agency can proceed with challenging HM Revenue & Customs' trimming of its value-added tax credit by about £187,000 ($253,000) after a court spiked the U.K. tax authority's bid for an early end to the case.

  • April 16, 2026

    UK Firms Wary Of Loan-Out Contracts, Paramount VP Says

    Companies across various industries are becoming more hesitant to employ people via loan-out firms because of concerns about their own tax liabilities, a Paramount Global vice president said Thursday.

  • April 16, 2026

    Texas Judge Vacates IRS' Steep Microcaptive Reporting Rule

    A Texas federal judge vacated a tax code regulation designating microcaptive insurance transactions as listed transactions subject to deep scrutiny and hefty penalties, saying the Internal Revenue Service didn't prove that they are mostly for tax avoidance and not really for insurance.

  • April 16, 2026

    Defunct Canada Law Firm Can't Get Bad Debt Tax Deduction

    A shuttered Canadian law firm can't get a tax break on unpaid client bills, the Tax Court of Canada ruled, holding that the firm didn't make a sufficient effort to chase down payments before claiming a bad debt deduction.

  • April 16, 2026

    OECD To Address Double-Tax Policy Quirk, Official Says

    The Organization for Economic Cooperation and Development is working to iron out a policy quirk that can result in double taxation when it is unclear whether restrictions on interest deductions fall under domestic tax rules or international treaty frameworks, an OECD official said Thursday.

  • April 16, 2026

    Canadian Bank Defeats Country-By-Country Tax Proposal

    Shareholders of the Canadian Imperial Bank of Commerce voted against a proposal to require the bank to disclose public country-by-country reports of tax information Thursday, with only about 10% of shareholders voting in favor.

  • April 15, 2026

    Centrica Loses £5.3M Tax Dispute Over North Sea Gas Field

    Centrica's activities in a North Sea natural gas field amount to oil extraction, and therefore the company is liable for corporate tax bills totaling £5.3 million ($7.2 million) under the rules governing energy taxation, according to a London tribunal.

  • April 15, 2026

    Cross-Border Services Taxes Are 'Quasi-Tariffs,' Report Says

    The U.S. arguably has a stronger interest in challenging digital services taxes and other "quasi-tariffs" than in pursuing tariffs on physical goods, according a report Wednesday from the Tax Foundation, which contended that these overseas taxes disproportionately harm large services exporters.

  • April 15, 2026

    UK Tribunal Says Director Owed Tax On Written-Off Loan

    The former director of a defunct U.K. company is on the hook for taxes and penalties after he failed to report a canceled debt to tax authorities, a U.K. court ruled Wednesday.

  • April 15, 2026

    Eaton Says Tax Court Can't Disregard Transfer Of $14B Asset

    The U.S. Tax Court can't disregard Eaton's transfer of a $14 billion asset overseas because the IRS itself didn't challenge the transaction's validity, the company argued Wednesday in defending the interest rates and guarantee fees paid to its Irish parent in 2012 and 2013.

  • April 15, 2026

    Builders Brace To Fight Tax Fraud 'Should Have Known' Test

    Britain's tax agency has begun to wield strengthened enforcement powers to combat tax fraud in the construction industry after reforms that lawyers warn could trigger disputes as businesses challenge whether they meet the regime's contentious "should have known" test.

  • April 15, 2026

    Orsted Loses Top UK Court Case Over Wind Farm Tax Break

    A Danish wind farm company cannot claim tax relief on pre-development costs for building wind farms, Britain's top court held Wednesday, ruling that the costs are not sufficiently connected to the provision of plants and machinery.

  • April 14, 2026

    Siemens Says It Met Conditions For $671M Deduction

    Siemens Medical Solutions is entitled to a $670.6 million foreign-dividend tax deduction because it met the three prerequisites set forth in the statute governing the deduction, the company told the U.S. Tax Court.

  • April 14, 2026

    Canada To Suspend Fuel Taxes Amid War In Iran

    Canada will temporarily suspend excise taxes on fuel, a CA$2.4 billion ($1.7 billion) expenditure aimed at combating price spikes linked to the U.S. and Israel's war in Iran, Prime Minister Mark Carney said Tuesday in his first action after winning a governing majority.

  • April 14, 2026

    IRS Audited 3% Of Rich Taxpayers Pegged As Flouting FATCA

    The IRS audited just 3% of taxpayers with $6.2 trillion offshore who were identified as noncompliant with the Foreign Account Tax Compliance Act and assessed no penalties to the vast majority of "egregious nonfilers," the Treasury Inspector General for Tax Administration said in a report.

  • April 14, 2026

    Customs Casts Doubt On Automating Certain Tariff Refunds

    U.S. Customs and Border Protection's automated tariff refund system is nearly complete, but thousands of imports may require a more cumbersome manual process that could undermine the agency's other priorities, an official told the U.S. Court of International Trade on Tuesday.

  • April 14, 2026

    Canada Appeals Court Denies Costs To Gov't In Tax Disputes

    Canada's government will not receive enhanced legal costs for tax disputes with two companies where it largely prevailed because it failed to demonstrate that related cases held in abeyance justified the extra award, according to the Federal Court of Appeal.

  • April 14, 2026

    2nd Circ. Urged To Rethink IRS Win In Foreign Reporting Case

    A New York business owner asked the Second Circuit to rethink a panel's decision that held the IRS could automatically assess and administratively collect certain foreign information reporting penalties, arguing that the ruling deepens a nationwide conflict about the agency's assessment authority.

Expert Analysis

  • Adapting To Private Practice: From Texas AUSA To BigLaw

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    As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.

  • Advice For 1st-Gen Lawyers Entering The Legal Profession

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    Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.

  • Trump Tax Law's Most Impactful Corp. And Individual Changes

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    The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.

  • From Clerkship To Law Firm: 5 Transition Tips For Associates

    Excerpt from Practical Guidance
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    Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.

  • Trump Tax Law's Most Consequential International Changes

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    The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.

  • Associates Can Earn Credibility By Investing In Relationships

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    As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.

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

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    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

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    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

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    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

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    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

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    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

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    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

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    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.

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