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June 08, 2026
Liberty Global Seeks Rehearing In $2.4B Tax Substance Fight
Telecommunications firm Liberty Global wants another shot at showing the Tenth Circuit that it's entitled to a $2.4 billion deduction linked to transactions with foreign affiliates, claiming the court misapplied a rule that can disallow tax benefits from transactions that lack economic substance.
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June 08, 2026
Energy Transactions Atty Returns To McGuireWoods In SF
A senior vice president with Aon's global mergers and acquisitions and transactions solutions team has rejoined McGuireWoods LLP as a partner in San Francisco, the firm announced Monday.
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June 08, 2026
McKesson Can't Defeat Valid Cost-Sharing Rules, Gov't Says
The U.S. government urged a Texas federal court to uphold transfer pricing regulations that pharmaceutical giant McKesson is challenging in its push for a nearly $10 million tax refund, arguing the rules fall "well within the bounds" of the underlying statutory text.
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June 06, 2026
Inheritance Tax Penalties Surge By 35%, Data Shows
Britain's tax authority imposed 35% more penalties for late inheritance tax returns in tax year 2024-25 compared with 2020-21, according to government data released by a law firm Saturday.
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June 05, 2026
11th Circ. Lets Man Fight $2.2M FBAR Penalties As Excessive
A Georgia federal court correctly found that the owner of a sports equipment business willfully failed to disclose his foreign bank accounts, but it must give him a chance to challenge $2.2 million in resulting penalties as excessive under the Eighth Amendment, the Eleventh Circuit said.
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June 05, 2026
Abbott Says Timing Mismatch Lets $8B Gain Go Untaxed
Abbott Laboratories asked the U.S. Tax Court to find that it needn't recognize an $8 billion gain in 2020 from transactions between several of its controlled foreign corporations because of a mismatch in the effective dates of different sections of the 2017 U.S. Tax Cuts and Jobs Act.
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June 05, 2026
HMRC's Reading Would Double-Tax £10M, Upper Tribunal Told
Shareholders of a holding company argued before the Upper Tribunal on Friday that HM Revenue & Customs misinterpreted tax legislation, risking the same £10 million ($13.4 million) in payouts being taxed twice after a capital reduction.
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June 05, 2026
Taxation With Representation: Simpson Thacher, Fried Frank
In this week's Taxation With Representation, Berkshire Hathaway Inc. takes Taylor Morrison Home Corp. private, global real estate investment company Kennedy Wilson forms a residential joint venture with Netherlands pension services provider APG, and Wellington Management acquires Hartford Funds from insurer The Hartford.
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June 05, 2026
Wife Of Bankrupt Former EY Tax Chief Sued By Trustees
The bankruptcy trustees of former EY head of tax John Dixon are bringing a claim against his wife, according to a newly public entry on the High Court's filing system.
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June 05, 2026
Irish Presidency Outlines Forecast For EU Tax Info Shake-Up
The incoming Irish presidency of the Council of the European Union outlined predictions for EU tax changes — including some related to information sharing — in a note to policy experts seen by Law360 on Friday.
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June 04, 2026
Feds Appeal Trade Court's Emergency Tariff Refund Order
The federal government has appealed the U.S. Court of International Trade's order requiring refunds on all duties paid under the International Emergency Economic Powers Act after the U.S. Supreme Court struck them down this year, according to filings in the trade court and Federal Circuit.
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June 04, 2026
HMRC Defends Tax Win In £10M Share Payout Dispute
The U.K.'s tax authority told a London court Thursday that a shareholder payout falls within anti-tax avoidance rules in a case concerning the tax treatment of £10 million ($13.4 million) in shares paid out following a capital reduction.
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June 04, 2026
Ex-Surgeon Agrees To $7.7M Tax Bill From Offshore Scheme
A retired plastic surgeon reached a $7.7 million settlement with the federal government to resolve an Internal Revenue Service case alleging that he ran an offshore employee leasing scheme, according to an agreement filed in an Ohio federal court.
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June 04, 2026
EU Tobacco Tax Bill Dropped From Upcoming Negotiations
Ambassadors from European Union countries failed to reach an agreement on a controversial EU tobacco taxation bill, according to an EU official, meaning the file has been withdrawn from the agenda of an upcoming meeting of member state finance ministers.
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June 04, 2026
EU Calls On Germany, Poland, Spain To Correct Tax Policies
The European Union's executive branch has called on Germany, Poland and Spain to end tax policies that it has determined violate the bloc's rules.
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June 04, 2026
OECD Urges Nations to Mull Tax Breaks In Pillar 2 Safe Harbor
Countries should "think carefully" about how their tax incentives will fit into a side-by-side safe harbor under the 15% global minimum corporate tax known as Pillar Two, the Organization for Economic Cooperation and Development said in a report released Thursday.
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June 04, 2026
HMRC Arrests Two Over Suspected £153M TikTok Tax Scam
The tax authority said Thursday that it had arrested two men suspected of using TikTok to perpetrate an alleged multi-million-pound tax fraud by persuading users to hand over tax account details with the promise of "quick cash."
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June 03, 2026
Texas Instruments Defends Deductions For Exercised Options
Texas Instruments challenged total deficiencies of $47.9 million for 2018 and 2019, much of it from the IRS' disallowance of deductions for deferred compensation, such as exercised stock options, under an approach consistent with a 2022 agency advice memorandum.
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June 03, 2026
UK Adults Unaware Of Inheritance Tax Relief, Insurer Says
Almost three-quarters of British adults don't know that certain gifts are exempt from inheritance tax as the fiscal rules for estates and pensions are set to change in April 2027, according to research published Wednesday.
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June 03, 2026
USTR Floats Double-Digit Tariffs On Basis Of Forced Labor
Sixty economies are facing added tariffs of either 10% or 12.5% on their exports to the U.S. following investigations by the U.S. Trade Representative's Office into countries' protections against the importing of goods produced with forced labor.
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June 03, 2026
Iran War Driving Slower Growth, Surging Inflation, OECD Says
The Iran war is driving slower growth and surging inflation across the global economy, and U.S. tariff policy is adding to uncertainty, the OECD said Wednesday during a virtual news conference.
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June 03, 2026
USTR Seeks Input On China Preferential Trade Mechanism
The Office of the U.S. Trade Representative announced what it is calling a government-to-government mechanism that will manage bilateral trade between the U.S. and China, including by considering tariff cuts, and asked for public comments on the program's development.
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June 03, 2026
Australia Considers Floating Tax Whistleblower Rewards
The Australian Treasury is seeking feedback on its tax whistleblowing framework, including whether the regime should offer financial incentives for exposing misconduct and whether current rules effectively protect those who already do.
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June 03, 2026
EU Court Upholds Denial Of Late VAT Correction
European Union law on value-added tax does not prevent member states from restricting VAT corrections after the closure of an audit period, an EU court said Wednesday, provided that the taxpayer had a reasonable opportunity to correct the submission before the deadline.
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June 02, 2026
Brazil Facing 25% US Tariff Over IP, Other 'Unfair Practices'
The U.S. Trade Representative proposed hitting Brazil with a broad 25% tariff following a trade investigation that it says uncovered a slew of "unfair practices that imposed burdens on American businesses," including poorly enforced intellectual property rights and preferential tariffs.
Barclays Loses VAT Appeal Over UK Fixed Establishment
A Barclays entity lacked a fixed establishment in the U.K. because its British branch was "skeletal" when the Delaware-based company applied for value-added tax grouping, a London tribunal ruled Monday.
Developers Stumped By Energy Credits' Foreign Debt Limits
Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.
Calif.'s Global Reporting Bill Could Embolden Other States
A California bill that would require multinational corporations to report their global profits could spark similar legislation across the U.S. if lawmakers of revenue-hungry states perceive shortcomings in federal and international efforts to tackle profit shifting.
Featured Stories
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Developers Stumped By Energy Credits' Foreign Debt Limits
Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.
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Calif.'s Global Reporting Bill Could Embolden Other States
A California bill that would require multinational corporations to report their global profits could spark similar legislation across the U.S. if lawmakers of revenue-hungry states perceive shortcomings in federal and international efforts to tackle profit shifting.
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Int'l Tax In May: Tariff Refunds Begin, New Levies Thrown Out
The U.S. Court of International Trade held last month that the temporary tariffs imposed by President Donald Trump under Section 122 of the Trade Act are illegal, and companies saw the first refunds of the levies they were meant to replace. The European Union, meanwhile, strengthened the safeguards in the trade deal it reached with the U.S. last year. Here, Law360 looks at some of the biggest international tax developments from May.
Expert Analysis
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5 Things Associates Must Ask About Their Firm's Merger Plan
The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.
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2 'Rocket Dockets' And The Rules That Propel Them
The fastest civil trial courts in the country are currently in the Eastern District of Virginia and the Southern District of Florida, and their chief judges provide insights into the court rules that keep them ahead, says Robert Tata at Hunton.
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Your Next Litigation Hold Should Cover AI Chat Logs
The Delaware Chancery Court’s recent decision in Fortis Advisors v. Krafton to treat a CEO’s artificial intelligence chats as substantive evidence is being read as a discovery warning to litigators, but there is a second duty-to-preserve lesson that is especially pertinent to in-house counsel, say attorneys at Faegre Drinker.
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Studying Foreign Languages Makes Me A Better Lawyer
Studying Italian and Japanese has shown me that learning a new language can benefit a legal career in several ways, including by demonstrating the importance of approaching problems from a fresh perspective and the value of practicing patience with colleagues and clients, says Anna King at Genworth Financial.
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Sold Inventory May Drive Tax Treatment Of Tariff Refunds
Companies determining the tax treatment of refunds expected following the U.S. Supreme Court's February decision invalidating tariffs imposed under the International Emergency Economic Powers Act should consider whether the tariff costs have already reduced their income considering the cost of goods sold, say attorneys at McDermott.
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Adapting To AI-Driven Scrutiny Of Foreign Asset Disclosures
As the government expands AI-driven, cross-agency fraud detection, foreign asset disclosure should be viewed as part of a broader, data‑driven enforcement ecosystem that prioritizes consistency, documentation and proactive governance, says Logan Koehring at FBT Gibbons.
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Tax Teams Get No Bright-Line Rule From AI Privilege Cases
Three recent appellate decisions that considered artificial intelligence in the context of attorney-client privilege protections illustrate that taxpayers and tax practitioners alike must consider the pertinent facts on a case-by-case basis, with particular attention to confidentiality, disclosure risk and system design, say attorneys at Morgan Lewis.
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NY Times Word Puzzles Make Me A Better Lawyer
Every morning I let The New York Times humble me with word games, which offer a chance to recalibrate my brain before the day's chaos arrives and remind me that a solution — whether to a puzzle or employment law issue — almost always exists once I find the right angle, says Amy Epstein Gluck at Pierson Ferdinand.
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Law School's Missed Lesson: Diagnose Before Arguing
Law school often skips over explicitly teaching students how to determine what kind of problem a case presents before they commit to a particular doctrinal path, which risks building arguments that are internally coherent but externally misaligned, says Melanie Oxhorn at Kobre & Kim.
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Judges On AI: How Courts Can Survive The Tech Revolution
Colorado Supreme Court Justice Maria Berkenkotter and Colorado Court of Appeals Judge Lino Lipinsky de Orlov discuss how artificial intelligence has already fundamentally altered the legal system and offer tips for courts navigating deepfakes, hallucinations and a gap in access to AI tools.
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3 AI Adoption Mistakes GCs Should Avoid
The pressure in-house legal teams face to quickly adopt artificial intelligence tools, combined with budget constraints and the need to evaluate a crowded market of options, sets the stage for implementation mistakes that are often difficult to undo, says former 23andMe general counsel Guy Chayoun.
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4 Emerging Approaches To AI Protective Order Language
Over the last year, at least five federal district courts have issued or analyzed specific protective order provisions restricting the use of generative artificial intelligence platforms with protected materials, establishing that proactive AI-specific provisions are now standard practice and demonstrating that no single model works for every case, says Joel Bush at Kilpatrick.
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Heppner Ruling Left AI Privilege Risk For Lawyers Unresolved
While a New York federal judge’s recent ruling in U.S. v. Heppner resolved a privilege question surrounding client-side artificial intelligence use, it did not address how to mitigate the risks that can arise when confidential information enters the operative context of an AI system used by an attorney, says Jianfei Chen at Quarles & Brady.