International
- 
									July 18, 2025
									Law360 Names 2025's Top Attorneys Under 40Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age. 
- 
									July 18, 2025
									Trade Legal Matters To Watch: Midyear ReportAggressive, sweeping tariff actions have defined the first six months of President Donald Trump's second term, altering the global trade environment in attempts to return manufacturing to the U.S. and reset trading deficits, but legal challenges to certain duties may obstruct Trump's long-term trade strategy in ongoing negotiations later this year. 
- 
									July 18, 2025
									HMRC Urged To Broaden Reporting Of Uncertain Tax PositionsHM Revenue & Customs may need to change its rules for when taxpayers must disclose uncertain tax positions they've taken to the tax authority, according to a report by a nonprofit research organization. 
- 
									July 18, 2025
									IRS Offers Guidance On Use Of Transfer Pricing ExceptionTaxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday. 
- 
									July 18, 2025
									Trump Asks Supreme Court To Decline Early Tariff ChallengePresident Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts. 
- 
									July 18, 2025
									Western Union Says IRS Used Flawed Rule To Hike IncomeThe Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court. 
- 
									July 18, 2025
									Taxation With Representation: Wachtell, Slaughter And MayIn this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award. 
- 
									July 18, 2025
									European Tax Policy To Watch In 2nd Half Of 2025The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months. 
- 
									July 18, 2025
									EU To Make Foreign Traders Liable For VAT On ImportsForeign companies, rather than consumers, will become liable for value-added tax on imports to the European Union beginning July 2028 under a directive adopted Friday by the bloc's council of member states, according to a news release. 
- 
									July 18, 2025
									Oman, Trinidad And Tobago 'Largely Compliant,' OECD SaysReviews of the implementation of tax transparency measures in Oman and in Trinidad and Tobago found both nations "largely compliant" with Organization for Economic Cooperation and Development standards, the OECD said Friday. 
- 
									July 17, 2025
									Canada Mulling Changes To Ability To Rewrite TransactionsCanada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday. 
- 
									July 17, 2025
									US Negotiating Global Min. Tax Carveout Accord, Official SaysThe U.S. hasn't yet secured an agreement with other countries to exempt its companies from the international parts of the 15% global minimum tax despite reaching an "understanding" with the Group of 7 nations, but wider negotiations have begun, a U.S. Treasury Department official said Thursday. 
- 
									July 17, 2025
									EU Warns Dutch Over Tax Breaks Favoring Foreign InvestmentThe Netherlands may have to face the Court of Justice of the European Union if it does not amend a tax measure that provides incentives for investment in foreign companies over domestic businesses, the European Commission announced Thursday. 
- 
									July 17, 2025
									EU Lawmakers Push For Tax Data Hub To Combat EvasionMembers of the European Parliament approved proposals for tax changes across the European Union, including a tax data hub to streamline compliance across the bloc and help combat tax avoidance and evasion. 
- 
									July 17, 2025
									US Challenge To Belgian Minimum Tax Rules Heads To ECJA Belgian court said Thursday it has asked the European Union's highest court to weigh in on a U.S. industry group's challenge to the country's global minimum tax rules. 
- 
									July 17, 2025
									Tax Info Swaps Have Generated €135B Since 2009, OECD SaysThe international push for widespread adoption of tax transparency measures such as exchanges of information has led to €135 billion ($156 billion) in added revenue — including taxes, penalties and interest — since 2009, the Organization for Economic Cooperation and Development said Thursday. 
- 
									July 17, 2025
									Australia Seeks Comments On Pillar 2 GuidanceThe Australian Taxation Office is looking for public comments on a pair of draft guidelines related to the country's adoption of the Organization for Economic Cooperation and Development's Pillar Two global corporate minimum tax on large multinational entities. 
- 
									July 16, 2025
									OECD Mulling Tweaks To Arm's-Length Range GuidanceThe Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday. 
- 
									July 16, 2025
									Tax Losses Back Retired Prof's FBAR Penalties, US SaysA retired professor's admission in U.S. Tax Court that his failure to report his foreign bank accounts caused tax losses shows that a California federal court should affirm tax penalties against him of more than $400,000, the U.S. government said. 
- 
									July 16, 2025
									EU Proposes New Tax On Large Cos. In Budget For 2028-2034The European Commission raised the idea Wednesday of a new tax on all companies that operate in the European Union with more than €100 million ($116 million) in annual revenue to augment its €2 trillion budget proposal for 2028 through 2034. 
- 
									July 16, 2025
									German Chancellor Calls For EU Halt To Global Minimum TaxGerman Chancellor Friedrich Merz has called for the suspension of the European Union's rollout of the global corporate minimum tax, a German newspaper reported Wednesday. 
- 
									July 16, 2025
									USTR To Probe Brazil's Trade Practices For Possible TariffsThe Office of the U.S. Trade Representative announced Tuesday evening it will launch an investigation into Brazil's trade practices to determine whether tariff actions could be necessary after a request by President Donald Trump and prior tariff threats. 
- 
									July 16, 2025
									India Uses AI In Fraudulent Tax Crackdown, Recovers $122MA sweeping enforcement operation by the Indian tax authority used artificial intelligence and third-party financial data to uncover widespread abuse of tax deductions and exemptions, so far recovering 1,045 crore rupees ($122 million), the government said. 
- 
									July 16, 2025
									Freight Co. Loses Interim Bid To Lift HMRC Export ControlsA warehouse operator and drinks merchant have lost a bid for interim relief against U.K. tax authority export controls imposed over tax fraud concerns, with a London court ruling they had an "uphill task" to prove the measures were unreasonable. 
- 
									July 15, 2025
									Trump Says US Has Struck Trade Deal With IndonesiaPresident Donald Trump announced Tuesday that the U.S. has reached a trade deal with Indonesia that includes a 19% tariff on all goods exported by the Southeast Asian country to the U.S., while American goods exported there will be free of tariffs. 
Expert Analysis
- 
								
								This Earth Day, Consider How Your Firm Can Go Greener  As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies. 
- 
								
								Cum-Ex Prosecutions Storm Shows No Sign Of Abating  The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli. 
- 
								
								Practicing Law With Parkinson's Disease  This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease. 
- 
								
								Why Supreme Court Should Allow Repatriation Tax To StandIf the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein. 
- 
								
								For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill  A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson. 
- 
								
								Requiring Leave To File Amicus Briefs Is A Bad Idea  A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center. 
- 
								
								4 Ways To Motivate Junior Attorneys To Bring Their Best  As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten. 
- 
								
								Former Minn. Chief Justice Instructs On Writing Better Briefs  Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench. 
- 
								
								Stay Interviews Are Key To Retaining Legal Talent  Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey. 
- 
								
								Neb. Justices Should Weigh IRC Terms In Dividend Tax Case  Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan. 
- 
								
								Judicial Independence Is Imperative This Election Year  As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College. 
- 
								
								Spartan Arbitration Tactics Against Well-Funded Opponents  Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable. 
- 
								
								What Recent Study Shows About AI's Promise For Legal Tasks  Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.