International

  • March 12, 2026

    Tariff Refund System Taking Shape, US Customs Tells CIT

    U.S. Customs and Border Protection is making progress developing a system for importers to claim refunds for the global tariff regime struck down by the U.S. Supreme Court, an official told the U.S. Court of International Trade on Thursday.

  • March 12, 2026

    Microsoft, Michigan Settle Cost-Share Receipts Tax Fight

    Microsoft and Michigan reached a settlement over the company's challenge to the state's tax treatment of its cost-sharing agreement receipts with foreign affiliates, according to a dismissal order entered Thursday by the state's Tax Tribunal.

  • March 12, 2026

    IRS Allows 15% Of KFC Parent's Domestic Production Claim

    The IRS and the parent of Pizza Hut, KFC and Taco Bell agreed that the company's total deductions for domestic production activities during 2013-2015 were $1.6 million — roughly 15% of the $10.7 million the company had claimed as deductions for the three years.

  • March 12, 2026

    Reeves Says Energy Windfall Tax May Not Apply By Late 2027

    The U.K.'s energy profits levy is expected to no longer apply to oil and gas operations in the North Sea in the last quarter of 2027, especially if the current Middle East crisis de-escalates and energy prices stabilize, Chancellor of the Exchequer Rachel Reeves told an H&M Treasury committee.

  • March 12, 2026

    Alleged IRS Errors Don't Merit Injunction, Judge Advises

    A Puerto Rico magistrate judge recommended denying a taxpayer's bid to block the IRS from assessing her tax liabilities while the agency's clerical errors that she alleges remain unresolved, holding that she faces uncertainties that don't rise to the level of irreparable harm.

  • March 11, 2026

    Costco Owes Shoppers Refunds For Voided Tariffs, Suit Says

    Costco shoppers are owed back the higher costs they paid as a result of President Donald Trump's global tariffs that the nation's highest court has since declared unlawful, according to a putative consumer class action filed Wednesday in Illinois federal court.

  • March 11, 2026

    Cos. Ask Court To Toss Trump's Revamped Global Tariffs

    Two companies are challenging President Donald Trump's revamped global tariff regime, telling the U.S. Court of International Trade that the circumstances required to justify the regime cannot exist.

  • March 11, 2026

    Dairy Giant Loses Bid For UK Tax Deductions On IP Transfers

    A London court on Wednesday dismissed a European dairy giant's appeal seeking corporate tax deductions for intellectual property transferred to the partnership by its corporate members.

  • March 11, 2026

    EU Refers Spain To Top Court For Inaction On VAT Directives

    Spain will be referred to the European Union's top court for failing to incorporate two legal directives on value-added tax into Spanish law by a December 2024 deadline, the EU's executive arm said Wednesday.

  • March 11, 2026

    Transfer Pricing Cases Collected £3.4B Last Year, HMRC Says

    The U.K. brought in £3.4 billion ($4.6 billion) in additional revenue from transfer pricing cases from 2024-2025, nearly double the amount from the previous year, according to HM Revenue & Customs data released Wednesday.

  • March 11, 2026

    Barrister's Libel Claim Against Neidle Dismissed As SLAPP

    A judge has struck out a barrister's £8 million ($11 million) libel claim against Dan Neidle, ruling on Wednesday that the case had no chance of succeeding and amounted to a strategic legal claim designed to silence the legal blogger. 

  • March 10, 2026

    Hewlett Packard To Fight IRS Transfer Pricing Adjustments

    Hewlett Packard Enterprise Co. disagrees with transfer pricing adjustments by the IRS and will challenge the agency's efforts to increase its taxable income, the company said in a quarterly report released Tuesday.

  • March 10, 2026

    Exxon Wins $27M Deduction In Canadian Tax Dispute

    The Tax Court of Canada backed Exxon Mobil's bid for a CA$36.2 million ($26.7 million) income deduction for expenses tied to an abandoned Alaskan pipeline project, holding that the company incurred the costs while conducting legitimate business operations.

  • March 10, 2026

    PE Group Asks 3rd Circ. To Overturn Fund's $100M Tax Bill

    The U.S. economy could face damaging consequences if the Third Circuit upholds a U.S. Tax Court decision finding a Cayman Islands hedge fund liable for a $100 million tax bill as a securities dealer, a private equity lobbying group told the court.

  • March 10, 2026

    French Tax Take Outpaces Economic Growth

    France's net tax revenue reached €610 billion ($710 billion) in fiscal year 2025, growing three times faster than GDP, the French tax authority said Tuesday.

  • March 10, 2026

    Portugal Warns Of Carbon Tax Abuse If Exemptions Granted

    A more lenient application of the European Union's carbon leakage tax in the bloc's outermost regions would risk tax evasion, Portugal's finance minister said during a meeting to discuss the bloc's economic agenda.

  • March 10, 2026

    Alston & Bird Adds Deals Pro From Proskauer To Tax Team

    Alston & Bird LLP announced on Tuesday that it has welcomed a tax attorney from Proskauer Rose LLP, saying that his hire will benefit its transactional team and its private equity clients.

  • March 09, 2026

    2nd Circ. Says COVID Policy Saves Argentine Creditors' Case

    The Second Circuit on Monday revived a $5.5 million contractual dispute against Argentina, ruling that a New York state COVID-19 policy saved some bondholder claims from being time-barred.

  • March 09, 2026

    Mining Co. Weighs Arbitration With Mozambique Tax Authority

    An Irish mining company said Monday it's considering international arbitration for a dispute with the Mozambique Tax Authority over the agency's imposition of higher royalties during negotiations on renewing an investment agreement.

  • March 09, 2026

    Omni Bridgeway Gets Green Light To Target Albania Assets

    A Washington, D.C., federal judge agreed to let litigation funder Omni Bridgeway seize assets belonging to the Albanian government as it looks to enforce an arbitral award now worth some $13 million that the country has ignored for years.

  • March 09, 2026

    Hotel Fund Can't Challenge Tax Method Again, Tribunal Says

    A property fund's appeal against the U.K. tax authority's decision to reject its claim to £5.2 million ($6.96 million) in tax relief for the cost of renovating a hotel near London Luton Airport was dismissed by a London tribunal, which said the matter was already decided.

  • March 09, 2026

    Canadian Funds Can't Block IRS Bank Summons, Court Says

    Two Cayman-Canadian investment funds cannot block IRS summonses made on behalf of the Canadian government for daily trading records at a U.S. bank because they failed to show the agency didn't tick the right boxes, a New York federal court said.

  • March 06, 2026

    Customs Faces Hurdles In $166B Tariff Refund Order

    U.S. Customs and Border Protection no longer needs to immediately refund Trump administration tariffs that were struck down by the U.S. Supreme Court after the U.S. Court of International Trade loosened a previous order Friday in response to the agency warning compliance was impossible.

  • March 06, 2026

    Clean Energy Tax Credit Market Thrives Despite New Limits

    The market for selling clean energy tax credits continues to thrive despite the 2025 budget law's stricter eligibility rules for solar and wind incentives, with more corporations embracing the ability to buy those credits as a streamlined method to shrink their tax liabilities.

  • March 06, 2026

    Taxation With Representation: Slaughter And May, Kirkland

    In this week's Taxation With Representation, British insurer Beazley accepts a cash takeover offer from Zurich Insurance Group, a consortium of investors led by Blackrock's Global Infrastructure Partners and the EQT Infrastructure VI fund buys energy company AES, and private equity firm Thoma Bravo acquires third-party logistics provider WWEX.

Featured Stories

  • Clean Energy Tax Credit Market Thrives Despite New Limits

    Kat Lucero

    The market for selling clean energy tax credits continues to thrive despite the 2025 budget law's stricter eligibility rules for solar and wind incentives, with more corporations embracing the ability to buy those credits as a streamlined method to shrink their tax liabilities.

  • UK's Planned Mansion Tax Starts To Shape Property Sales

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    The U.K. government's plan for a surcharge on properties worth more than £2 million ($2.7 million), known as the mansion tax, is beginning to influence the market for such properties ahead of the tax's rollout in two years, experts told Law360.

  • Int'l Tax In February: Check On US Tariffs Prompts Reactions

    Molly Moses

    Over the past month, new U.S. Internal Revenue Service rules on clean fuel and energy tax credits have brought certainty for some taxpayers, even as the end of tariffs imposed under the U.S. International Emergency Economic Powers Act has created new uncertainty around recent trade deals with India and the European Union. Here, Law360 looks at the biggest international tax developments in February.

Expert Analysis

  • 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.

  • AI-Generated Doc Ruling Guides Attys On Privilege Risks

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    A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.

  • The Law Firm Merger Diaries: Leadership Strategy After Day 1

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    For law firm leaders, ensuring a newly combined law firm lives up to its promise, both in its first days of operation and well after, includes tough decisions, clear and specific communication, and cheerleading, says Peter Michaud at Ballard Spahr.

  • Calif.'s Civility Push Shows Why Professionalism Is Vital

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    The California Bar’s campaign against discourteous behavior by attorneys, including a newly required annual civility oath, reflects a growing concern among states that professionalism in law needs shoring up — and recognizes that maintaining composure even when stressed is key to both succeeding professionally and maintaining faith in the legal system, says Lucy Wang at Hinshaw.

  • US-Ukraine Reconstruction Fund Tax Exemptions Uncertain

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    Tax provisions in the bilateral agreement to establish the U.S.-Ukraine Reconstruction Investment Fund, which recently announced it is accepting applications, are so broad and imprecise as to leave uncertainty regarding whether and when tax exemptions will apply to investors' income, say attorneys at Avellum and Debevoise.

  • Trivia Competition Makes Me A Better Lawyer

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    Playing trivia taught me to quickly absorb information and recognize when I've learned what I'm expected to know, training me in the crucial skills needed to be a good attorney, and reminding me to be gracious in defeat, says Jonah Knobler at Patterson Belknap.

  • Judges On AI: Practical Use Cases In Chambers

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    U.S. Magistrate Judge Allison Goddard in the Southern District of California discusses how she uses generative artificial intelligence tools in chambers to make work more efficient and effective — from editing jury instructions for clarity to summarizing key documents.

  • Malpractice Claim Assignability Continues To Divide Courts

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    Recent decisions from courts across the country demonstrate how different jurisdictions balance competing policy interests in determining whether legal malpractice claims can be assigned, providing a framework to identify when and how to challenge any attempted assignment, says Christopher Blazejewski at Sherin & Lodgen.

  • NYC Bar Opinion Warns Attys On Use Of AI Recording Tools

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    Attorneys who use artificial intelligence tools to record, transcribe and summarize conversations with clients should heed the New York City Bar Association’s recent opinion addressing the legal and ethical risks posed by such tools, and follow several best practices to avoid violating the Rules of Professional Conduct, say attorneys at Smith Gambrell.