International

  • February 06, 2026

    Taxation With Representation: Gibson Dunn, S&C, Wachtell

    In this week's Taxation With Representation, Elon Musk announces SpaceX's acquisition of his artificial intelligence company xAI, Devon Energy and Coterra Energy agree to merge, and Banco Santander SA acquires Webster Financial Corp.

  • February 06, 2026

    CPAs Suggest Treasury Scrap Doc Plans For CFC Rules

    The U.S. Treasury Department should rethink planned documentation requirements for overseas income allocations, the American Institute of Certified Public Accountants recommended in a letter released Friday, saying the rules may be unnecessarily burdensome.

  • February 05, 2026

    Russian Scientist's US Wages Not Tax-Exempt, Tax Court Says

    The U.S. Department of Energy's payments to a Russian scientist for subatomic particle research in Virginia don't fall under a U.S.-Russia tax treaty covering tax-exempt grants, the U.S. Tax Court held Thursday.

  • February 05, 2026

    UN Talks Aim To Identify Gaps On Harmful Tax Practices

    Representatives of governments asked their colleagues Thursday to pinpoint gaps in ongoing efforts to address harmful tax practices in order to sharpen the United Nations' framework convention on international tax cooperation.

  • February 05, 2026

    Ga. Law Firm's CTA Challenge 'Hypothetical,' Feds Argue

    The U.S. Treasury Department has asked a federal judge to toss a Georgia lawyer's suit alleging that the 2021 Corporate Transparency Act could force him to violate attorney-client privilege, arguing the suit is based on future "hypothetical changes" to the federal policy of nonenforcement.

  • February 05, 2026

    Hostages Aren't Receiving Tax Relief, TIGTA Says

    Recently released hostages did not receive tax relief despite the Internal Revenue Service implementing new procedures to improve the process to provide tax relief to taxpayers wrongfully detained or taken hostage, the Treasury Inspector General for Tax Administration said in a report released Thursday.

  • February 04, 2026

    Developing Nations See Tax Data Swaps Lacking Reciprocity

    Developing countries' requests for taxpayer information are often denied by other countries even as the resource-strapped nations have invested resources in fulfilling incoming requests, government officials said Wednesday.

  • February 04, 2026

    Tax Group Of The Year: Davis Polk

    Davis Polk & Wardwell LLP scored a significant victory for Exxon Mobil in litigation concerning the tax treatment of a major partnership with Qatar and oversaw several other complex, high-stakes transactions, earning it recognition as a 2025 Law360 Tax Practice Group of the Year.

  • February 04, 2026

    IRS Urges Tax Court To Cut $315M From Siemens Deduction

    The Internal Revenue Service defended its slashing of $315 million from a tax deduction that medical giant Siemens claimed on payments from overseas, telling the U.S. Tax Court that rule writers had congressional backing to issue the regulations underpinning the adjustment.

  • February 04, 2026

    Walmart Wants Relief In CFC Tax Year Deferral

    Walmart asked the U.S. Department of the Treasury to temporarily allow certain taxpayers to file a single 13-month return, instead of two separate returns, in the wake of filing changes regarding controlled foreign corporations, according to a letter released Wednesday.

  • February 04, 2026

    One Essex Court Barrister Sued For Negligence In £32M Case

    Billionaire Michael Platt and his hedge fund have accused a One Essex Court barrister of negligence by failing to set out two key appeal arguments in a dispute with tax authorities over a £32.25 million ($44 million) charge.

  • February 03, 2026

    Dairy Co. Presses UK Court To Revive Tax Deductions On IP

    A European dairy giant asked a London appeals court on Tuesday to overturn lower tribunal rulings denying the company tax deductions for the gradual write-off of brands, intellectual property and goodwill following an acquisition.

  • February 03, 2026

    Gov'ts Resist Binding Treaty Renegotiations In UN Tax Pact

    Several governments expressed opposition Tuesday to a proposed requirement for countries to renegotiate bilateral tax treaties in line with principles aimed at fairly allocating taxing rights as part of the United Nations framework convention on international tax cooperation.

  • February 03, 2026

    IRS Floats Clean Fuel Credit Rules With Foreign Restrictions

    The Internal Revenue Service released long-awaited proposed regulations Tuesday clarifying how domestic transportation fuel producers can qualify for the clean energy fuel tax credit under changes made by Republicans' 2025 budget law, including new foreign restrictions on business owners and feedstock sources.

  • February 03, 2026

    French Gov't Approves Budget With New Corp. Tax Measures

    The French government has adopted a budget that targets wealthy people and corporations, including a surtax on the country's biggest companies that is expected to bring in €7.3 billion ($8.6 billion).

  • February 03, 2026

    Virgin Islands Co. Wants Experts Barred In $11.5M Pricing Row

    A U.S. Virgin Islands mortgage company challenging the territorial government over $11.5 million in tax bills asked a federal court Tuesday to exclude expert testimony meant to bolster the government's case that the company wrongly claimed a tax break meant to help the local economy.

  • February 03, 2026

    HMRC Disputes Danish Wind Farm's Tax Relief At Top Court

    Britain's tax authority told the U.K. Supreme Court on Tuesday that a Danish wind farm company can't claim tax relief on pre-development costs for building wind farms, because the costs are too remote from the actual provision of plants and machinery.

  • February 02, 2026

    Int'l Tax In January: Global Min. Reached, Trade Deals Abound

    January was a busy month in international tax, starting with an agreement by nearly 150 countries on a global minimum tax that effectively exempts U.S. companies and culminating with trade deals between Canada and China as well as India and the European Union. Here, Law360 looks at the biggest developments in international tax over the last month.

  • February 02, 2026

    Trump, Modi Say US-India Trade Deal Reached

    President Donald Trump said Monday he reached a trade deal with India following a call with Prime Minister Narendra Modi that includes lowering the tariff rate on Indian goods entering the U.S. from 50% to 18%.

  • February 02, 2026

    Spencer Fane Expands To New Orleans With Litigation Hire

    Spencer Fane LLP announced that an experienced Louisiana-based attorney from Phelps Dunbar LLP has joined the firm's litigation and dispute resolution team as a partner, marking the fast-growing firm's initial foray into the New Orleans market.

  • February 02, 2026

    India To Provide Tax Break For Cloud Service Providers

    India will implement several tax measures designed to attract multinational corporations, including a "tax holiday" for foreign companies that provide cloud services using the country's data services, the government announced.

  • February 02, 2026

    US Drops $185K FBAR Case Amid State Dept. Silence

    The U.S. Department of Justice dropped its case Monday accusing a U.S. citizen living in Switzerland of hiding bank accounts from the IRS, telling a D.C. federal court that the U.S. Department of State fell silent on a request for help from Swiss authorities.

  • February 02, 2026

    OECD Amends Tax Treaty Manual To Up Dispute Resolution

    The Organization for Economic Cooperation and Development is updating guidance for tax treaties to strengthen tax treaty mechanisms for preventing cross-border tax disputes, according to a statement Monday.

  • February 02, 2026

    EU Loses €14B In Taxes Annually From US Cos., Report Says

    European Union member states are losing €14 billion ($16.5 billion) in revenues each year as a result of tax avoidance by U.S. companies, Tax Justice Network warned Monday ahead of international tax talks.

  • February 02, 2026

    Norton Rose Grows In Key Cities By Adding 5 Polsinelli Attys

    Norton Rose Fulbright announced Monday that it has added five former Polsinelli PC shareholders as partners to grow its transactional and healthcare capabilities in two key U.S. markets.

Expert Analysis

  • Judges On AI: How Courts Can Boost Access To Justice

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    Arizona Court of Appeals Judge Samuel A. Thumma writes that generative artificial intelligence tools offer a profound opportunity to enhance access to justice and engender public confidence in courts’ use of technology, and judges can seize this opportunity in five key ways.

  • The Case For Emulating, Not Dividing, The Ninth Circuit

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    Champions for improved judicial administration should reject the unfounded criticisms driving recent Senate proposals to divide the Ninth Circuit and instead seek to replicate the court's unique strengths and successes, says Ninth Circuit Judge J. Clifford Wallace.

  • 5 Tariff And Trade Developments To Watch In 2026

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    A new trade landscape emerged in 2025, the contours of which will be further defined by developments that will merit close attention this year, including a key ruling from the U.S. Supreme Court and a review of the U.S.-Mexico-Canada Agreement, says Ted Posner at Baker Botts.

  • 4 Developments That Defined The 2025 Ethics Landscape

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    The legal profession spent 2025 at the edge of its ethical comfort zone as courts, firms and regulators confronted how fast-moving technologies and new business models collide with long-standing professional duties, signaling that the profession is entering a period of sustained disruption that will continue into 2026, says Hilary Gerzhoy at HWG Law.

  • How Fractional GCs Can Manage Risks Of Engagement

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    As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.

  • How OECD Tax Update Tackles Mobile Workforce Complexity

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    The Organization for Economic Cooperation and Development’s recently updated model tax convention — a recalibration of international tax principles in response to an increasingly mobile workforce — should prompt companies to reevaluate cross-border operations, transfer pricing policies and tax controversy strategies, say attorneys at Eversheds.

  • A Uniform Federal Rule Would Curb Gen AI Missteps In Court

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    To address the patchwork of courts’ standing orders on generative artificial intelligence, curbing abuses and relieving the burden on judges, the federal judiciary should consider amending its civil procedure rules to require litigants to certify they’ve reviewed legal filings for accuracy, say attorneys at Shook Hardy.

  • Supreme Court Term Limits Would Carry Hidden Risk

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    While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.

  • Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave

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    The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.

  • AI Evidence Rule Tweaks Encourage Judicial Guardrails

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    Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.

  • The Law Firm Merger Diaries: Getting The Message Across

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    Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.

  • Horizontal Stare Decisis Should Not Be Casually Discarded

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    Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.

  • 10 Commandments For Agentic AI Tools In The Legal Industry

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    Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.

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