International

  • January 13, 2026

    Pair Say IRS Records Undercut US In $1.8M Tax Dispute

    Internal Revenue Service documents show that a formerly married couple's refund claim was properly received, undermining the government's position that they improperly filed a refund claim for tax penalties of over $1.8 million relating to a foreign trust, they told a Pennsylvania federal court.

  • January 13, 2026

    IRS Asks 3rd Circ. To Uphold $100M Bill Against Hedge Fund

    The Internal Revenue Service urged the Third Circuit to uphold a $100 million tax bill against a Cayman Islands hedge fund, arguing that the fund's U.S.-based investment manager carried out a domestic business beyond merely securing capital.

  • January 12, 2026

    Trump Says 25% Tariff Incoming For Iranian Biz Dealings

    Any country with economic ties to Iran could face a 25% tariff immediately on their goods exported to the U.S., President Donald Trump said Monday on social media.

  • January 12, 2026

    European Union Carrying Out Revised Min. Corp. Tax Regime

    The European Union's executive body is implementing changes to the 15% minimum corporate tax regime across the trade bloc after a renegotiation of Pillar Two last week, according to a notice published Monday.

  • January 12, 2026

    Solar Co. Blames Broker's Error For $6M Tariff Bill

    A renewable energy company wants its customs broker and agent held responsible for over $6 million in antidumping and countervailing duties it had to pay on imported solar panels due to the broker's alleged failure to properly record them.

  • January 12, 2026

    India High Court Rules Post-Merger Shares Can Be Taxed

    The Supreme Court of India ruled that if companies combine to create a new business with shares that are worth more than those of the individual corporations, investors may owe taxes on the difference in value.

  • January 12, 2026

    OECD Issues Guidance On Real-Time Reporting For VAT

    The OECD has released guidance for policymakers on designing mandates for real-time reporting of transactions to tax authorities for value-added tax purposes, which are increasingly being considered and adopted by countries worldwide.

  • January 09, 2026

    US Disputes Right To Trial Before IRS Assesses FBAR Fines

    A California man wasn't entitled to a jury trial prior to the IRS assessing penalties for his failure to report foreign bank accounts because the U.S. Supreme Court decision he cited limiting administrative courts for securities fraud doesn't apply, the government told a California federal court.

  • January 09, 2026

    EU Council Approves Trade Pact With 4 S. American Countries

    A legislative arm of the European Union approved the bloc's free trade agreement with four South American countries Friday, taking steps to create the largest global free trade zone.

  • January 09, 2026

    Taxation With Representation: King & Spalding, Torys, Milbank

    In this week's Taxation With Representation, power generation company Vistra Corp. acquires Cogentrix Energy from Quantum Capital Group, real estate firm Minto Group partners with Crestpoint Real Estate Investments to take Minto's apartment-focused real estate investment trust private, and engineering services provider Jacobs acquires a remaining stake in PA Consulting.

  • January 09, 2026

    China To Cut VAT Export Tax Rebates For Solar Panels

    China will eliminate its value-added tax export rebates for photovoltaic and other related products starting April 1, the country's Ministry of Finance said Friday.

  • January 09, 2026

    UK Gov't Rules Out Farm Inheritance Tax Concessions

    The U.K.'s Labour government will not make more concessions to farmers on its inheritance tax rule changes for agricultural land after a recent compromise on the tax threshold, a minister said in a speech at a conference.

  • January 08, 2026

    OECD, Gov't Officials Praise 'Side-By-Side' Tax Deal

    Officials from Germany, the U.S. and the OECD on Thursday hailed a recently finalized agreement among roughly 150 countries as a balanced solution to the U.S.' desire for a global minimum tax regime that operates "side by side" with its own rules.

  • January 08, 2026

    Courts Back Agencies Despite Loper Bright Ruling, DOJ Says

    Appellate courts have mostly upheld federal agencies' interpretation of ambiguous statutes, including tax disputes, even after the U.S. Supreme Court's 2024 landmark decision that limited agency deference, a U.S. Department of Justice attorney said Thursday.

  • January 08, 2026

    US Asks 6th Circ. To Revive Reg In $89M FedEx Tax Suit

    The Sixth Circuit should vacate a judgment that allowed FedEx an $89 million refund by discarding a regulation preventing companies from claiming foreign tax credits on earnings offset by losses, which aren't taxed in the U.S., the government said in an opening brief.

  • January 08, 2026

    Irish R&D Tax Credit Linked To €7B In Spending, Gov't Says

    Ireland's tax credit for research and development is linked to €7 billion ($8.2 billion) in related spending by companies on the island in 2023 while costing the government about €1.4 billion, the Irish Department of Finance said Thursday.

  • January 08, 2026

    Data Supervisor Warns Against Exceptional VAT Info Searches

    The European Union's plans to crack down on value-added tax fraud may blur the line between data cooperation and law enforcement, potentially undermining data protection, the EU's data supervisor warned Thursday.

  • January 08, 2026

    Audits Get Final Word On Economic Substance, IRS Atty Says

    IRS attorneys provide legal guidance during audits on whether a transaction lacks economic substance, but examiners make the ultimate determination, an agency associate chief counsel said Thursday while explaining how the agency applies a powerful anti-abuse tool in audits.

  • January 08, 2026

    HSBC To Pay €300M To Settle French Tax Fraud Probe

    HSBC has agreed to pay French authorities more than €300 million ($350 million) in fines and unpaid taxes to settle a criminal probe into how the bank's Paris branch handled dividend arbitrage transactions between 2014 and 2019, public prosecutors revealed Thursday.

  • January 08, 2026

    OECD Project Seeks To Ease Access To Tax Dispute Process

    A new project at the OECD will aim to ensure that double-tax cases are eligible to be resolved through bilateral government negotiations under treaties no matter how they're characterized by a country's tax authority, a U.S. Treasury Department official said Thursday.

  • January 07, 2026

    US Official Gives Rationale For OECD Global Mobility Changes

    Recent changes to the commentary on when a home office gives rise to a permanent establishment in the OECD model tax treaty reflect delegates' unhappiness with previous language on the availability of an office, a U.S. Treasury Department official said Wednesday.

  • January 07, 2026

    Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says

    The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed Swiss account, the Second Circuit said Wednesday, upholding a lower court's judgment.

  • January 07, 2026

    Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies

    The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025.

  • January 07, 2026

    Gov't Slow-Rolling Lower Fee For Expatriation, Court Told

    The U.S. State Department has impermissibly slow-walked the rollout of a reduced fee for renouncing U.S. citizenship, a Paris-based group that represents Americans permanently residing abroad told a D.C. federal court.

  • January 07, 2026

    Australia Increasingly Blocking Tax Debtors From Leaving

    The Australian Taxation Office is increasingly barring international travel for people with tax debts who it suspects of trying to flee their obligations, it said Wednesday.

Expert Analysis

  • The Bar Needs More Clarity On The Discovery Objection Rule

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    Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.

  • So You Want To Move Your Law Practice To Canada, Eh?

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    Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.

  • Promoting Diversity In The Selection Of ADR Neutrals

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    Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.

  • Striking A Balance Between AI Use And Attorney Well-Being

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    As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.

  • How Judiciary Can Minimize AI Risks In Secondary Sources

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    Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.

  • How Attorneys Can Break Free From Career Enmeshment

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    Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.

  • Lawyers With Disabilities Are Seeking Equity, Not Pity

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    Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.

  • Judicial Committee Best Venue For Litigation Funding Rules

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    The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.

  • The Strategic Advantages Of Appointing A Law Firm CEO

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    The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.

  • How Cos. Can Build A Strong In-House Pro Bono Program

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    During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.

  • Home Canning Makes Me A Better Lawyer

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    Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.

  • Use The Right Kind Of Feedback To Help Gen Z Attorneys

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    Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.

  • Congress Can And Must Enact A Supreme Court Ethics Code

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    As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.

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