International

  • October 07, 2025

    11th Circ. Wary Of IRS Procedure In FBAR Penalty Appeal

    An Eleventh Circuit panel Tuesday appeared concerned about IRS procedures that could keep a man from recouping $419,000 he paid to resolve his failure to disclose funds held in foreign bank accounts as he appeals a district court determination that he actually owes $2.2 million.

  • October 07, 2025

    Senate OKs Top Treasury Atty Pick In Slate Of Confirmations

    The Senate approved President Donald Trump's choice of a Sidley Austin LLP partner to be general counsel of the U.S. Department of the Treasury on Tuesday as part of a combined confirmation of 108 nominees to various roles.

  • October 07, 2025

    German States Vote Against Suspending Global Minimum Tax

    A majority of Germany's states voted against a motion to suspend the 15% global minimum tax while the international community is resolving a U.S. proposal to exempt American companies from most of the system, two state finance ministries told Law360 on Tuesday.

  • October 07, 2025

    Ireland Plans To Revise Laws On Tax Breaks For Interest

    Ireland's Finance Department is working on an overhaul to laws covering tax deductions for interest, it announced Tuesday, saying it expects to submit amendments to lawmakers next year that focus on areas like aligning the tax treatment of foreign interest income from trading and passive sources.

  • October 07, 2025

    IRS Provides Grace Period For Int'l Money Transfer Tax Errors

    U.S. financial institutions that handle overseas money transfers won't immediately face penalties if they fail to accurately deposit new excise taxes that are required under the budget reconciliation bill enacted in July, the Internal Revenue Service announced Tuesday.

  • October 06, 2025

    Fed. Circ. Partially Revives German Steel Co.'s Dumping Suit

    The U.S. Commerce Department cannot use a German steelmaker's likely sales prices as a proxy for the cost of producing nonprime steel plates, but the company acted too late to argue for categorizing some plates separately as it challenges Commerce's antidumping investigation, the Federal Circuit said Monday.

  • October 06, 2025

    IRS Cyber Crime Executive Named Interim Compliance Chief

    An Internal Revenue Service criminal investigations executive who founded the division's cyber crimes sections will temporarily take on an elevated role overseeing all agency enforcement operations, the IRS announced Monday.

  • October 06, 2025

    Italian Police Seize Assets In Suspected €43M Car VAT Fraud

    Italian police seized cars, bank accounts, real estate and luxury goods connected to a suspected scheme to evade nearly €43 million ($50 million) in value-added taxes on luxury cars imported from Germany, the European Public Prosecutor's Office said Monday.

  • October 06, 2025

    London Casino Loses Dispute Over VAT Base Method

    HM Revenue & Customs used the correct method for calculating the value-added tax base of a casino, a London court ruled Monday, rejecting the casino's arguments for the use of a special method that would have allowed it to recover more input VAT.

  • October 06, 2025

    Social Security Chief Adds Duties As Inaugural CEO Of IRS

    The current administrator of the Social Security Administration is adding a new role as the Internal Revenue Service's first chief executive officer, Treasury Secretary Scott Bessent announced Monday.

  • October 03, 2025

    28% Of Large Cos. In Australia Paid No Income Tax Last Year

    The share of large companies operating in Australia that paid no income taxes dropped below 30% for the first time during the 2023-2024 period, the Australian Taxation Office said, attributing this to officials curbing tax avoidance.

  • October 03, 2025

    Indian Gov't Report Floats Fixed Profit Rates For Foreign Cos.

    India should revise its permanent establishment rules by introducing an optional scheme to assign fixed profit rates by industry or business model, which would reduce litigation by foreign businesses over profit attribution methods, a government think tank said Friday.

  • October 03, 2025

    Some Longtime Legal Blogs Go Quiet As Platform Shuts Down

    When the online publishing platform Typepad launched more than two decades ago, it became a hub for a then-growing community of law professors and legal bloggers. Its closure this week marked the end of an era that has found some bloggers looking for new homes or opting to call it quits.

  • October 03, 2025

    DC Circ. Split On Challenge To IRS-ICE Info-Sharing Deal

    D.C. Circuit judges seemed split Friday over whether an information-sharing agreement between immigration authorities and the IRS complies with taxpayer privacy protections, with one judge noting during oral arguments that the government immigration arm requesting the tax information appears unauthorized to make the requests.

  • October 03, 2025

    Getting It Right: An Economist On Transfer Pricing

    Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.

  • October 03, 2025

    Mining Cos. Warn Of OECD Guidance's Transfer Pricing Risks

    Mining companies and other stakeholders raised concerns over transfer pricing risks and possible tax disputes arising from proposed guidance on pricing copper exports, according to documents published by the Organization for Economic Cooperation and Development.

  • October 03, 2025

    Taxation With Representation: Kirkland, Paul Weiss, Cravath

    In this week's Taxation With Representation, video game maker Electronic Arts agrees to be acquired by the Saudi Arabia Public Investment Fund, Silver Lake and Affinity Partners; online mortgage giant Rocket closes its acquisition of rival Mr. Cooper Group; and Berkshire Hathaway acquires international energy company Occidental's chemical business.

  • October 03, 2025

    Denmark's £1.4B Cum-Ex Loss Raises Legal Strategy Doubts

    Denmark's "bruising" defeat in its £1.4 billion ($1.9 billion) cum-ex fraud case against trader Sanjay Shah and others calls into question its legal strategy and the scope of its claim, lawyers have said, although they believe an appeal appears inevitable.

  • October 03, 2025

    Denmark Denied Permission To Appeal £1.4B Cum-Ex Defeat

    Denmark cannot revive its £1.4 billion ($1.9 billion) against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.

  • October 02, 2025

    IRS Data-Sharing Case Won't Be Paused For Gov't Shutdown

    The U.S. Department of Justice must still submit court-ordered information in a lawsuit challenging the Internal Revenue Service's sharing of tax data with immigration authorities by Oct. 24, a D.C. federal judge ruled, despite the federal government shutdown that began Wednesday.

  • October 02, 2025

    German States Push To Halt Min. Tax As US Seeks Exemption

    Three German states said they would ask the country's other states Thursday to push the federal government to suspend the 15% global minimum tax in Germany while the U.S. proposal to exempt American companies from most of the system is being resolved.

  • October 02, 2025

    Debt Recovery Actions Not Taxable Under EU Law, ECJ Says

    A holding company pursuing debt recovery is not providing a taxable service to its debtor under European value-added tax law, the European Union's top court ruled Thursday.

  • October 02, 2025

    Tax KC Sued By Hedge Fund Billionaire Over Negligence

    Billionaire Michael Platt and his hedge fund BlueCrest Capital Management have sued a senior One Essex Court barrister who represented them in a dispute with the U.K. tax authority over the identity of awards paid under a special partnership program. 

  • October 02, 2025

    Denmark Loses £1.4B Cum-Ex Fraud Case Against UK Trader

    Denmark lost on Thursday its £1.4 billion ($1.9 billion) legal claim against scores of traders and financial institutions over a cum-ex tax fraud it said was orchestrated by convicted hedge fund trader Sanjay Shah.

  • October 01, 2025

    Calif. Importer, Son Both Get Prison For $8M Customs Fraud

    A California federal judge sentenced a Los Angeles Fashion District business owner and his son to more than eight years and seven years in prison, respectively, after they were found guilty of ducking more than $8 million in customs duties and failing to report over $17 million in cash transactions on tax returns.

Expert Analysis

  • 4 Ways Women Attorneys Can Build A Legal Legacy

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    This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.

  • A Judge's Pointers For Adding Spice To Dry Legal Writing

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    U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.

  • 7 Tips For Associates To Thrive In Hybrid Work Environments

    Excerpt from Practical Guidance
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    As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.

  • IRS Should Revise Overbroad Microcaptive Regs

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    Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.

  • What's Next For Russia Sanctions After Task Force Disbanded

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    Attorney General Pam Bondi’s recent disbanding of Task Force KleptoCapture, which was initially aimed at seizing Russian oligarchs’ funds and assets, is unlikely to mean the end of Russia sanctions enforcement and other economic countermeasures, as the architecture for criminal enforcement remains in place, say attorneys at BakerHostetler.

  • How Law Firms Can Counteract The Loneliness Epidemic

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    The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.

  • 5 Keys To Building Stronger Attorney-Client Relationships

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    Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.

  • Attorneys Must Act Now To Protect Judicial Independence

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    Given the Trump administration's recent moves threatening the independence of the judiciary, including efforts to impeach judges who ruled against executive actions, lawyers must protect the rule of law and resist attempts to dilute the judicial branch’s authority, says attorney Bhavleen Sabharwal.

  • Rethinking 'No Comment' For Clients Facing Public Crises

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    “No comment” is no longer a cost-free or even a viable public communications strategy for companies in crisis, and counsel must tailor their guidance based on a variety of competing factors to help clients emerge successfully, says Robert Bowers at Moore & Van Allen.

  • Reading The Tea Leaves On Mexico, Canada And China Tariffs

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    It's still unclear whether the delay in the imposition of U.S. tariffs on Canadian and Mexican imports will result in negotiated resolutions or a full-on trade war, but the outcome may hinge on continuing negotiations and the Trump administration's possible plans for tariff revenues, say attorneys at Eversheds Sutherland.

  • How Design Thinking Can Help Lawyers Find Purpose In Work

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    Lawyers everywhere are feeling overwhelmed amid mass government layoffs, increasing political instability and a justice system stretched to its limits — but a design-thinking framework can help attorneys navigate this uncertainty and find meaning in their work, say law professors at the University of Michigan.

  • The Pros And Cons Of A 2nd Trump Term For UK Tech Sector

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    While U.S. President Donald Trump’s protectionist stance on trade could disrupt global supply chains on which many U.K. tech firms are reliant, anticipated deregulation could provide fertile ground for investment and growth, and the U.K. tech sector is bracing for a mix of opportunities, say lawyers at Shoosmiths.

  • Corp. Transparency Act's Future Under Treasury's Bessent

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    The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.

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