International
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February 12, 2026
Gov'ts Favor Optionality In UN Tax Treaty's Dispute Protocol
Governments widely supported having the ability to choose between options for dispute resolution and prevention while making an opt-out unavailable for some methods in the dispute protocol under the United Nations framework convention on international tax cooperation, according to negotiations on the protocol.
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February 12, 2026
Canadian Living In Wash. Says FBAR Penalty Required Jury
A Canadian man living in the U.S. was unconstitutionally fined more than $700,000 for failing to report his foreign bank accounts, he told a Washington federal court, arguing that the amount is excessive and that its assessment violates his right to a jury trial.
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February 12, 2026
Hotel Cos. Urge UK Gov't To Abandon Holiday Tax Proposal
The Labour government should not introduce what is known as a holiday tax on the hospitality industry, more than 200 hotel companies told the U.K.'s finance minister.
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February 12, 2026
Dinsmore Adds IRS Senior Counsel As Tax Partner In DC
An attorney who spent more than a decade working as an attorney and reviewer at the Internal Revenue Service has joined Dinsmore & Shohl LLP's Washington, D.C., tax group, the firm announced this week.
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February 12, 2026
Broker Says Denmark Can't Bring £56M Cum-Ex Fraud Claim
An English broker told Britain's top court on Thursday that Denmark's tax authority can't sue it for more than £56 million ($76 million) over a tax refund fraud, because an earlier decision in related proceedings rendered the claim inadmissible.
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February 11, 2026
House OKs Ending Canada Tariffs After GOP Block Fails
The U.S. House of Representatives approved a resolution Wednesday evening that would end President Donald Trump's tariffs on Canadian imports, a day after Republican lawmakers were unable to pass a measure blocking that kind of effort.
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February 11, 2026
Gov'ts Want Net Or Gross Option For Services In UN Tax Pact
There should be an option for taxpayers to elect gross-basis or net-basis taxation within the protocol on cross-border services under the United Nations framework convention on international tax cooperation, some governments said during negotiations on the protocol.
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February 11, 2026
'It Takes Time To Write': Jackson On High Court's Tariff Ruling
U.S. Supreme Court Justice Ketanji Brown Jackson has provided an unusual update on the court's decision over President Donald Trump's authority to impose emergency tariffs, saying in a TV interview that the justices are still working on what is one of their most anticipated rulings this term.
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February 11, 2026
Tax Group Of The Year: Sullivan & Cromwell
Sullivan & Cromwell LLP's tax practice showed the depth of its experience this past year, advising on multijurisdictional tax litigations to playing a key role counseling RedBird Capital Partners in a deal that merged Paramount and Skydance, helping it earn a place among the 2025 Law360 Tax Groups of the Year.
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February 11, 2026
Tax Advisers Urge EU To Scrap Disclosure Rules
The European Union should scrap rules requiring tax advisers to disclose potentially abusive cross-border strategies as it looks to update its regime for member countries' exchange of information, a European tax advisers group said.
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February 11, 2026
Morgan Lewis Adds 30-Year Baker McKenzie Atty, Ex-Tax Chair
The former chair of Baker McKenzie's Americas tax practice has joined Morgan Lewis & Bockius LLP's Washington, D.C., team, where he'll work as a partner on transfer pricing disputes and tax matters, the firm announced Wednesday.
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February 11, 2026
Denmark Says Cum-Ex Ruling No Bar To £56M Fraud Claim
Denmark told Britain's top court on Wednesday that it should be allowed to sue an English brokerage for £56 million ($76 million) over a tax refund fraud, arguing that an earlier decision barring linked allegations was based on "fundamentally different" facts.
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February 10, 2026
Gov'ts Want Varied Nexus In UN Treaty's Services Protocol
Business models should have different nexus rules that don't rely on physical presence in the protocol on cross-border services under the United Nations framework convention on international tax cooperation, governments said Tuesday.
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February 10, 2026
DOJ Drops Bid For Offshore Asset Freeze In $28M Tax Suit
The U.S. Department of Justice and a family of overseas-trust beneficiaries struck a partial deal in a $28 million tax suit in Florida federal court, with the DOJ dropping its push to freeze the family's assets and the family agreeing to temporarily limit their account withdrawals.
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February 10, 2026
Ex-Clifford Chance Pro Says £8M Libel Claim Is SLAPP
Legal commentator Dan Neidle asked a court on Tuesday to use new powers to throw out an £8 million ($11 million) libel claim accusing the former Clifford Chance partner of engaging in a vendetta against a barrister, arguing that the claim was launched to silence him.
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February 09, 2026
Gov'ts Back UN Treaty's Services Protocol Covering DSTs
All income taxes and digital services taxes should be covered by the protocol on cross-border services under the United Nations framework convention on international tax cooperation, many governments said Monday during negotiations regarding the protocol.
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February 09, 2026
DOD Employee Denies Laundering Millions For Scammers
A U.S. Department of Defense logistics specialist pled not guilty Monday to federal charges accusing him of laundering millions as part of an alleged Nigeria-based fraud scheme that targeted victims in the United States.
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February 09, 2026
$19M In Foreign Account Penalties Required Jury, Court Told
A U.S.-German citizen who failed to report his foreign accounts to the IRS told a Florida federal court that his $19 million punishment violates his right to a jury trial under a U.S. Supreme Court ruling that curbed the use of in-house agency courts to hand down stiff penalties.
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February 09, 2026
€306M Money Laundering Network Sting Leads To 13 Arrests
Law enforcement agencies in the European Union have arrested more than a dozen people in several raids after an investigation into a €306 million ($364.5 million) international money laundering scheme with links to drug trafficking and tax fraud.
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February 08, 2026
DOJ Drops Challenge To AbbVie's $1.6B Break Fee Deduction
The U.S. Department of Justice agreed to stop fighting a key U.S. Tax Court ruling that allowed pharmaceutical giant AbbVie to claim a $1.6 billion termination fee to an Irish biotechnology company as an ordinary tax deduction, according to a filing in the Seventh Circuit.
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February 08, 2026
HMRC Nets £246M In Evasion-Focused Inheritance Tax Probes
Britain's tax authority has recovered an additional £246 million ($336 million) in inheritance tax secured by investigations, according to data released Sunday.
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February 06, 2026
4 Takeaways From The EU's Latest Trade Agreements
The European Union recently cemented formal trade agreements with India and Mercosur, a group of Latin American countries, which — along with creating certainty for businesses in the regions — strike a sharp contrast with the approach taken in framework deals reached by President Donald Trump. Here, Law360 examines four takeaways from the two trade agreements announced by the EU.
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February 06, 2026
Trump Orders 25% Tariff For Countries With Biz Ties To Iran
President Donald Trump signed an executive order Friday afternoon that threatens a 25% tariff on the imports entering the U.S. of countries found to be purchasing goods or services from Iran.
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February 06, 2026
Partnership Asks Justices To Restore $23M Loss Deduction
A partnership asked the U.S. Supreme Court to revive its $23 million loss deduction involving a Brazilian company, saying in a petition docketed Friday that the Second Circuit wrongly blocked a key argument and that an IRS anti-abuse regulation applied against the partnership should be invalidated.
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February 06, 2026
Gov'ts Want Safeguards For Tax Data Swaps In UN Pact
The United Nations' framework convention on international tax cooperation must ensure that exchanges of taxpayer information take place only when the information is foreseeably relevant to the requesting government's enforcement of tax laws, several representatives said Friday during negotiations.
Expert Analysis
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5 Crisis Lawyering Skills For An Age Of Uncertainty
As attorneys increasingly face unprecedented and pervasive situations — from prosecutions of law enforcement officials to executive orders targeting law firms — they must develop several essential competencies of effective crisis lawyering, says Ray Brescia at Albany Law School.
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It's Time For The Judiciary To Fix Its Cybersecurity Problem
After recent reports that hackers have once again infiltrated federal courts’ electronic case management systems, the judiciary should strengthen its cybersecurity practices in line with executive branch standards, outlining clear roles and responsibilities for execution, says Ilona Cohen at HackerOne.
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Rules Of Origin Revamp May Be Next Big Trade Development
The rules of origin for determining what tariff applies to any given import appear to be on the cusp of an important rethink, and it seems likely that the administration will try to align the rule with its overall tariff strategy in one of three ways, says Ted Posner at Baker Botts.
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SDNY OpenAI Order Clarifies Preservation Standards For AI
The Southern District of New York’s recent order in the OpenAI copyright infringement litigation, denying discovery of The New York Times' artificial intelligence technology use, clarifies that traditional preservation benchmarks apply to AI content, relieving organizations from using a “keep everything” approach, says Philip Favro at Favro Law.
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High Court, Not A Single Justice, Should Decide On Recusal
As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
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Adapting To Private Practice: 3 Tips On Finding The Right Job
After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.
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Painting Makes Me A Better Lawyer
Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.
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Protecting Sensitive Court Filings After Recent Cyber Breach
In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.
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What Ethics Rules Say On Atty Discipline For Online Speech
Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.
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2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers
Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
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Junior Attys Must Beware Of 5 Common Legal Brief Mistakes
Excerpt from Practical Guidance
Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
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Power To The Paralegals: How And Why Training Must Evolve
Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.
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5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.