International
-
October 09, 2025
Dutch Gov't Summons Fund Suspected Of €200M Tax Evasion
Dutch prosecutors have summoned a foreign pension fund that they suspect evaded €200 million ($231 million) in taxes on dividends through fraudulent refund claims, the government said Thursday.
-
October 08, 2025
Trump Tariffs Unconstitutional, Watchdog Tells Justices
Either President Donald Trump doesn't have authority to impose tariffs under the International Emergency Economic Powers Act, or the law is unconstitutional, the nonprofit group Consumer Watchdog told the U.S. Supreme Court Wednesday, urging the justices to affirm lower court rulings deeming those measures unlawful.
-
October 08, 2025
3rd Time's The Charm? The Tax Court's Odyssey In Medtronic
A U.S. Tax Court judge has been sent back to the drawing board once again in the long-running transfer pricing litigation brought by Medtronic, raising questions about how much weight the court must give to IRS transfer pricing regulations and how much authority it has to go its own way.
-
October 08, 2025
EU Should Tax Super-Rich's' €405B Windfall, Oxfam Says
The European Union should implement a wealth tax to target the combined €405 billion ($471 billion) the super-rich made in the first six months of the year, charity Oxfam said in a report published Wednesday.
-
October 08, 2025
Crypto Debt Securities Open To Retail Investors, HMRC Says
U.K. retail investors now can include in their tax-advantaged savings accounts debt securities related to crypto-assets, which were previously limited to professional investors, HM Revenue & Customs announced Wednesday.
-
October 08, 2025
Tobacco Co. Made Timely Tax Refund Claims, UK Court Rules
A British tobacco company didn't wait too long to seek repayment of taxes it mistakenly paid on foreign dividends, a U.K. appeals court ruled Wednesday, rejecting HM Revenue & Customs' contention that the claims were time-barred.
-
October 08, 2025
Greece To Face CJEU Over Tax-Free Shops' Excise Exemption
Greece has continued to flout the European Union's rule against excise duty exemptions for goods sold at tax-free shops at borders with non-EU countries, the European Commission said Wednesday, announcing that it had referred the country to the Court of Justice of the European Union.
-
October 08, 2025
Denver Attorney Returns To Reed Smith State Tax Team
Reed Smith is expanding its tax practice with the return of an experienced attorney, now based in Denver, with multistate experience in the full spectrum of tax issues.
-
October 08, 2025
Charity Gifts In Wills Hit £1B As Estates Swerve Tax Bills
The value of charitable gifts left in people's wills climbed to £980 million ($1.3 billion) in the last financial year to April, as more Britons used philanthropy to reduce inheritance tax bills, London law firm TWM Solicitors LLP said Wednesday.
-
October 07, 2025
11th Circ. Wary Of IRS Procedure In FBAR Penalty Appeal
An Eleventh Circuit panel Tuesday appeared concerned about IRS procedures that could keep a man from recouping $419,000 he paid to resolve his failure to disclose funds held in foreign bank accounts as he appeals a district court determination that he actually owes $2.2 million.
-
October 07, 2025
Senate OKs Top Treasury Atty Pick In Slate Of Confirmations
The Senate approved President Donald Trump's choice of a Sidley Austin LLP partner to be general counsel of the U.S. Department of the Treasury on Tuesday as part of a combined confirmation of 108 nominees to various roles.
-
October 07, 2025
German States Vote Against Suspending Global Minimum Tax
A majority of Germany's states voted against a motion to suspend the 15% global minimum tax while the international community is resolving a U.S. proposal to exempt American companies from most of the system, two state finance ministries told Law360 on Tuesday.
-
October 07, 2025
Ireland Plans To Revise Laws On Tax Breaks For Interest
Ireland's Finance Department is working on an overhaul to laws covering tax deductions for interest, it announced Tuesday, saying it expects to submit amendments to lawmakers next year that focus on areas like aligning the tax treatment of foreign interest income from trading and passive sources.
-
October 07, 2025
IRS Provides Grace Period For Int'l Money Transfer Tax Errors
U.S. financial institutions that handle overseas money transfers won't immediately face penalties if they fail to accurately deposit new excise taxes that are required under the budget reconciliation bill enacted in July, the Internal Revenue Service announced Tuesday.
-
October 06, 2025
Fed. Circ. Partially Revives German Steel Co.'s Dumping Suit
The U.S. Commerce Department cannot use a German steelmaker's likely sales prices as a proxy for the cost of producing nonprime steel plates, but the company acted too late to argue for categorizing some plates separately as it challenges Commerce's antidumping investigation, the Federal Circuit said Monday.
-
October 06, 2025
IRS Cyber Crime Executive Named Interim Compliance Chief
An Internal Revenue Service criminal investigations executive who founded the division's cyber crimes sections will temporarily take on an elevated role overseeing all agency enforcement operations, the IRS announced Monday.
-
October 06, 2025
Italian Police Seize Assets In Suspected €43M Car VAT Fraud
Italian police seized cars, bank accounts, real estate and luxury goods connected to a suspected scheme to evade nearly €43 million ($50 million) in value-added taxes on luxury cars imported from Germany, the European Public Prosecutor's Office said Monday.
-
October 06, 2025
London Casino Loses Dispute Over VAT Base Method
HM Revenue & Customs used the correct method for calculating the value-added tax base of a casino, a London court ruled Monday, rejecting the casino's arguments for the use of a special method that would have allowed it to recover more input VAT.
-
October 06, 2025
Social Security Chief Adds Duties As Inaugural CEO Of IRS
The current administrator of the Social Security Administration is adding a new role as the Internal Revenue Service's first chief executive officer, Treasury Secretary Scott Bessent announced Monday.
-
October 03, 2025
28% Of Large Cos. In Australia Paid No Income Tax Last Year
The share of large companies operating in Australia that paid no income taxes dropped below 30% for the first time during the 2023-2024 period, the Australian Taxation Office said, attributing this to officials curbing tax avoidance.
-
October 03, 2025
Indian Gov't Report Floats Fixed Profit Rates For Foreign Cos.
India should revise its permanent establishment rules by introducing an optional scheme to assign fixed profit rates by industry or business model, which would reduce litigation by foreign businesses over profit attribution methods, a government think tank said Friday.
-
October 03, 2025
Some Longtime Legal Blogs Go Quiet As Platform Shuts Down
When the online publishing platform Typepad launched more than two decades ago, it became a hub for a then-growing community of law professors and legal bloggers. Its closure this week marked the end of an era that has found some bloggers looking for new homes or opting to call it quits.
-
October 03, 2025
DC Circ. Split On Challenge To IRS-ICE Info-Sharing Deal
D.C. Circuit judges seemed split Friday over whether an information-sharing agreement between immigration authorities and the IRS complies with taxpayer privacy protections, with one judge noting during oral arguments that the government immigration arm requesting the tax information appears unauthorized to make the requests.
-
October 03, 2025
Getting It Right: An Economist On Transfer Pricing
Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.
-
October 03, 2025
Mining Cos. Warn Of OECD Guidance's Transfer Pricing Risks
Mining companies and other stakeholders raised concerns over transfer pricing risks and possible tax disputes arising from proposed guidance on pricing copper exports, according to documents published by the Organization for Economic Cooperation and Development.
Expert Analysis
-
Firms Still Have The Edge In Lateral Hiring, But Buyer Beware
Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.
-
Think Like A Lawyer: 1 Type Of Case Complexity Stands Out
In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.
-
Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity
Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.
-
Litigation Inspiration: Reframing Document Review
For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.
-
3 Ways To Train Junior Lawyers In 30 Minutes Or Less
Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.
-
The Bar Needs More Clarity On The Discovery Objection Rule
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?
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
Excerpt from Practical Guidance
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
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
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
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
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
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.