International

  • December 17, 2025

    Treasury Issues Final Rule On BEAT For Securities Lending

    Taxpayers must determine and account for certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax, according to a final rule released Wednesday by the U.S. Department of the Treasury.

  • December 17, 2025

    EU Looks To Expand CBAM To Machinery, Other Products

    The European Union has proposed expanding its carbon border adjustment mechanism beyond basic materials to cover certain steel- or aluminum-intensive products like machinery and appliances, saying it wants to prevent spurring emissions-heavy production outside the bloc.

  • December 17, 2025

    Brazil's New Dividend Tax Rules To Impose 10% Withholding

    Dividends and profits paid by Brazilian entities to nonresidents will generally be subject to a 10% withholding tax starting in the new year, the country's revenue agency said in recent guidance, adding that 2025 distributions must be approved before the end of this year to avoid the new tax.

  • December 17, 2025

    Tax Authorities Shared Data 5,500 Times In 2024, OECD Says

    Tax authorities exchanged information on tax rulings 5,500 times last year as part of the base erosion and profit-shifting rules developed by the Organization for Economic Cooperation and Development, according to a report published Wednesday.

  • December 17, 2025

    UK Supreme Court Tosses Hotel's Atty Fee VAT Appeal

    A hotel company can't reclaim value-added tax paid on fees to lawyers and accountants as part of selling a subsidiary to finance the opening of a new hotel, the U.K. Supreme Court ruled Wednesday.

  • December 16, 2025

    Corporate Transparency Act Is Constitutional, 11th Circ. Says

    The Corporate Transparency Act is constitutional because it regulates economic activities with a substantial impact on interstate commerce and doesn't violate protections against unreasonable searches, the Eleventh Circuit said Tuesday, reversing a lower court's decision.

  • December 16, 2025

    Developing Nations Expand Corporate Tax Breaks, OECD Says

    Low- and middle-income countries generally expanded corporate tax incentives in 2024, while some coupled those measures with tax increases, the OECD reported Tuesday.

  • December 16, 2025

    Fired Top Antitrust Official Warns Of 'Politicization'

    The former No. 2 at the U.S. Department of Justice's Antitrust Division until he was terminated this year testified Tuesday about the "politicization" of antitrust enforcement.

  • December 17, 2025

    CORRECTED: Trade Court Nixes Injunction In Trump Tariff Suit

    The U.S. Court of International Trade has denied a preliminary injunction in a suit challenging President Donald Trump's emergency tariffs after auto part retailers failed to convince the court that the relief was necessary to preserve their potential right to refunds.

  • December 16, 2025

    Morrisons Owes £17M VAT On Chicken Sales, Tribunal Rules

    A London tribunal ruled that WM Morrison Supermarkets should have paid £17 million ($22.8 million) value-added tax on rotisserie chickens because the product qualifies as "hot food."

  • December 23, 2025

    Sullivan & Cromwell Hires Kirkland Pair For London Office

    Sullivan & Cromwell LLP said Tuesday that it has hired two new partners from Kirkland & Ellis LLP in London, boosting the firm's private equity and tax capabilities as it continues to expand in the City.

  • December 15, 2025

    UK Trader Couldn't Have Known Of VAT Fraud, Court Says

    Despite its "cavalier approach to due diligence," a scrap metal trader in the U.K. couldn't have known its suppliers were engaged in value-added tax fraud, so it isn't liable for additional tax and penalties, the First-tier Tribunal Tax Chamber said in a decision.

  • December 15, 2025

    UAE Clarifies Corp. Tax Liability Calculations

    The United Arab Emirates has amended its corporate tax law to clarify certain tax liability calculations, including how to factor in credits for withholding and foreign taxes, Abu Dhabi's state news agency said Monday.

  • December 15, 2025

    Cash Withdrawn From Online Biz Taxable, Tax Court Finds

    A man who received no paycheck from the online electronics business he ran in 2012 and 2013 but used its funds to purchase luxury vehicles and help a friend should have reported those amounts as taxable income, the U.S. Tax Court held Monday.

  • December 15, 2025

    Fed. Court Asked To Block IRS' Microcaptive Reporting Rule

    A Texas federal court should vacate an IRS rule aimed at flagging potential tax avoidance by requiring companies to disclose information about their microcaptive insurance transactions because it undermines Congress' authority, according to a Texas plastics company and its microcaptive adviser.

  • December 15, 2025

    Former Montana Insurer Wants Income Exclusion

    A Montana insurance company that dissolved in 2023 is challenging the IRS' determination that transactions it engaged in with an entity on the Turks and Caicos Islands didn't actually involve insurance and therefore aren't deductible for 2021.

  • December 15, 2025

    MPs Launch Inquiry Into Large Business Tax Compliance

    HM Revenue & Customs is facing an inquiry over its handling of tax compliance among large businesses, a parliamentary committee announced.

  • December 12, 2025

    Judge Says Eaton Moved $14B Subsidiary For Tax Purposes

    A U.S. Tax Court judge said Friday that he plans to find Eaton's U.S. group transferred ownership of a $14 billion subsidiary overseas in 2012 solely to justify payment of higher interest rates and guarantee fees to the company's new Irish parent.

  • December 12, 2025

    DOJ Shake-Up Keeps Criminal Tax Meetings, Ex-Official Says

    The U.S. Department of Justice — despite recently eliminating its Tax Division as part of a broad restructuring — continues to meet with practitioners representing clients who may face federal criminal tax charges, the former division chief said Friday.

  • December 12, 2025

    IRS To Revamp Voluntary Disclosure Program

    The Internal Revenue Service will be updating a program early next year that would allow taxpayers to voluntarily report previously undisclosed income as a way to resolve their tax issues to facilitate a simpler reporting process, the agency's criminal enforcement chief said Friday.

  • December 12, 2025

    Treasury Issues Final Rules For Taxing Foreign Gov't Income

    The U.S. Treasury Department issued final regulations Friday for determining whether income of foreign governments derived within the U.S. is taxable along with proposed regulations concerning when a foreign government has effective control of a commercial entity.

  • December 12, 2025

    Taxation With Representation: Cravath, Skadden, Debevoise

    In this week's Taxation With Representation, Paramount Skydance Corp. launches a hostile bid for Warner Bros. Discovery, challenging Netflix's deal to acquire the studio and streaming business, IBM acquires data streaming company Confluent, and natural gas company Antero Resources Corp. expands via a deal with HG Energy.

  • December 11, 2025

    Judge Slams Eaton Expert For Offering Legal Analysis

    A report submitted by one of Eaton's expert witnesses in its acquisition financing trial overstepped the limits of an expert's role, offering legal rather than economic analysis and seeming to advocate for the company​​​​, a U.S. Tax Court judge said Thursday.

  • December 11, 2025

    Fed Terminates 3 Actions Against Credit Suisse, JPMorgan

    The Federal Reserve said Thursday that it has terminated a trio of enforcement actions against Credit Suisse Group AG and JPMorgan Chase & Co., lifting consent orders that were tied to alleged illicit finance practices and trade surveillance failures.

  • December 11, 2025

    Wealth Taxes Can Succeed Despite Flaws, EU Panel Hears

    Wealth taxes have underperformed across the European Union because of design flaws, but this doesn't mean such levies can't work or that there are no alternatives, tax experts said Thursday.

Expert Analysis

  • 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.

  • A Simple Way Courts Can Help Attys Avoid AI Hallucinations

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    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

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    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.

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