International

  • December 23, 2025

    IRS Issues FAQs For Interest Expense Deduction Limits

    The Internal Revenue Service issued answers Tuesday to a set of frequently asked questions related to interest expense deduction calculations that were changed under the budget reconciliation law.

  • December 23, 2025

    The Biggest UK Commercial Fraud Cases In 2025

    Denmark's stinging defeat in a £1.4 billion ($1.9 billion) tax fraud claim and a U.K. Supreme Court ruling that widens the net for individuals who facilitate fraud are among the defining moments in the biggest commercial fraud cases of 2025.

  • December 22, 2025

    10th Circ. Tosses Plumbing Co.'s Captive Deduction Bid

    The Tenth Circuit is not the proper forum for a Utah plumbing company to challenge the Internal Revenue Service's 2016 notice denying a microcaptive insurance deduction, the appeals court found Monday, citing two statutes that bar the company's arguments.

  • December 22, 2025

    Draft House Bill Would Clarify Tax Rules For Digital Assets

    A bipartisan draft bill in the U.S. House would modernize the federal tax code for digital assets, its backers said, by establishing a "commonsense tax treatment" for regulated payment stablecoins, clarifying source-of-income rules for trading and extending existing securities-lending rules to digital assets.

  • December 22, 2025

    Top Federal Tax Policies Of 2025

    The first year of President Donald Trump's second term brought the passage of this summer's budget reconciliation bill, which renewed major parts of the 2017 Tax Cuts and Jobs Act, and major staffing changes at the Internal Revenue Service. Here, Law360 looks at the most consequential developments in federal tax policy in 2025.

  • December 22, 2025

    Tariff Refunds Would Be 'A Mess,' Economic Official Says

    It would be an "administrative problem" to issue tariff refunds in the aftermath of a potential U.S. Supreme Court ruling against the White House's trade measures, a top economic policy official said.

  • December 22, 2025

    IRS Seeks Input On Updates To Voluntary Disclosure Process

    The Internal Revenue Service asked Monday for comments on a proposed change to its voluntary disclosure program that would require payment of all taxes, penalties and interest within three months after being conditionally approved for the program.

  • December 19, 2025

    EU High Court Advised To Force Portugal To Reclaim Taxes

    The European Union's top court should rule that Portugal can't allow tax enforcement proceedings to be suspended in the case of unlawful state aid granted by the Madeira Free Zone, an adviser to the court said.

  • December 19, 2025

    Trade Court Remands Canada Lumber Duty Calculation Again

    The U.S. Commerce Department again failed to sufficiently justify how it calculated a subsidy rate in an antidumping duty administrative review for a Canadian exporter of softwood lumber products, the U.S. Court of International Trade said.

  • December 19, 2025

    Taxation With Representation: Baker Botts, Morgan Lewis

    In this week's Taxation With Representation, Trump Media and Technology Group merges with fusion power company TAE Technologies, pharmaceutical company Cencora boosts its stake in cancer care company OneOncology, and Phoenix Financial partners with private equity giant Blackstone to plug billions into various credit strategies.

  • December 19, 2025

    Calif. Ex-Customs Broker Sentenced For Tax, Wire Fraud

    A California man was sentenced to 51 months in federal prison after being indicted this year on federal fraud charges and one count of tax evasion, the U.S. Department of Justice said.

  • December 19, 2025

    Polsinelli Lands Glaser Weil Tax Pro In Los Angeles

    Polsinelli PC is expanding its business team, bringing in a tax pro from Glaser Weil as a shareholder in its Los Angeles office.

  • December 18, 2025

    Czech Republic, Estonia Shift To Backing Min. Tax Deal For US

    The Czech Republic and Estonia have shifted to supporting the proposed U.S. exemption from the global minimum tax's international provisions at the global tax policymaking body hosted by the Organization for Economic Cooperation and Development, the countries' finance ministries told Law360.

  • December 18, 2025

    Australia Issues Guidance On Min. Tax For Merged Accounts

    Australia's tax authority released several guidance documents detailing how the global minimum tax interacts with separate laws on accounting consolidation for corporate groups, as well as issues related to mismatched fiscal years among constituent entities.

  • December 18, 2025

    Denmark Files To Appeal £1.4B Cum-Ex Fraud Case Defeat

    Denmark has launched its effort to revive its £1.4 billion ($1.8 billion) case over a tax fraud allegedly orchestrated by convicted hedge fund trader Sanjay Shah, according to court filings seen by Law360 Thursday.

  • December 18, 2025

    HMRC Wins Burden Of Proof Query In £54M Tax Fraud Case

    A London appeals court ruled Thursday that HM Revenue & Customs doesn't bear the burden of proof in its tax liability claim against a British businessman it alleges used a company to commit alcohol smuggling and tax evasion of over £54 million ($72.2 million), plus penalties.

  • December 17, 2025

    Court Remands Commerce Ruling On Vietnam Steel Duties

    The U.S. Department of Commerce did not properly substantiate its 2023 findings that imports of Vietnamese steel products were flouting duties imposed on South Korea, India and China, the U.S. Court of International Trade said, remanding the agency's determinations.

  • December 17, 2025

    Ex-Biden Tax Counsel To Chair Willkie Tax Resolution Team

    Willkie Farr & Gallagher LLP has hired a former senior tax counsel who worked in two Democratic presidential administrations to come on board as chair of the firm's tax resolution practice group, according to a Wednesday announcement.

  • December 17, 2025

    EU Looking To Merge Tax Directives Into Single Instrument

    The European Commission is considering consolidating the nine bloc directives on administrative taxation cooperation — which cover such areas as the Organization for Economic Cooperation and Development's global minimum tax, crypto-asset reporting and cross-border tax rulings — into one legal instrument.

  • December 17, 2025

    Treasury Issues Final Rule On BEAT For Securities Lending

    Taxpayers must determine and account for certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax, according to a final rule released Wednesday by the U.S. Department of the Treasury.

  • December 17, 2025

    EU Looks To Expand CBAM To Machinery, Other Products

    The European Union has proposed expanding its carbon border adjustment mechanism beyond basic materials to cover certain steel- or aluminum-intensive products like machinery and appliances, saying it wants to prevent spurring emissions-heavy production outside the bloc.

  • December 17, 2025

    Brazil's New Dividend Tax Rules To Impose 10% Withholding

    Dividends and profits paid by Brazilian entities to nonresidents will generally be subject to a 10% withholding tax starting in the new year, the country's revenue agency said in recent guidance, adding that 2025 distributions must be approved before the end of this year to avoid the new tax.

  • December 17, 2025

    Tax Authorities Shared Data 5,500 Times In 2024, OECD Says

    Tax authorities exchanged information on tax rulings 5,500 times last year as part of the base erosion and profit-shifting rules developed by the Organization for Economic Cooperation and Development, according to a report published Wednesday.

  • December 17, 2025

    UK Supreme Court Tosses Hotel's Atty Fee VAT Appeal

    A hotel company can't reclaim value-added tax paid on fees to lawyers and accountants as part of selling a subsidiary to finance the opening of a new hotel, the U.K. Supreme Court ruled Wednesday.

  • December 16, 2025

    Corporate Transparency Act Is Constitutional, 11th Circ. Says

    The Corporate Transparency Act is constitutional because it regulates economic activities with a substantial impact on interstate commerce and doesn't violate protections against unreasonable searches, the Eleventh Circuit said Tuesday, reversing a lower court's decision.

Expert Analysis

  • Considerations When Invoking The Common-Interest Privilege

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    To successfully leverage the common-interest doctrine in a multiparty transaction or complex litigation, practitioners should be able to demonstrate that the parties intended for it to apply, that an underlying privilege like attorney-client has attached, and guard against disclosures that could waive privilege and defeat its purpose, say attorneys at DLA Piper.

  • The Law Firm Merger Diaries: Making The Case To Combine

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    When making the decision to merge, law firm leaders must factor in strategic alignment, cultural compatibility and leadership commitment in order to build a compelling case for combining firms to achieve shared goals and long-term success, says Kevin McLaughlin at UB Greensfelder.

  • What To Watch As NY LLC Transparency Act Is Stuck In Limbo

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    Just about a month before it's set to take effect, the status of the New York LLC Transparency Act remains murky because of a pending amendment and the lack of recent regulatory attention in New York, but business owners should at least prepare for the possibility of having to comply, says Jonathan Wilson at Buchalter.

  • Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar

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    Deputy Attorney General Todd Blanche’s recent suggestion that the D.C. Bar would be prevented from reviewing misconduct complaints about U.S. Department of Justice attorneys runs contrary to federal statutes, local rules and decades of case law, and sends the troubling message that federal prosecutors are subject to different rules, say attorneys at HWG.

  • 8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright

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    The Eighth Circuit’s recent decision invalidating transfer pricing regulations in 3M Co. v. Commissioner may be the most significant tax case implementing Loper Bright's rejection of agency deference as a judicial tool in statutory construction, says Edward Froelich at McDermott.

  • Rule Amendments Pave Path For A Privilege Claim 'Offensive'

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    Litigators should consider leveraging forthcoming amendments to the Federal Rules of Civil Procedure, which will require early negotiations of privilege-related discovery claims, by taking an offensive posture toward privilege logs at the outset of discovery, says David Ben-Meir at Ben-Meir Law.

  • Litigation Funding Could Create Ethics Issues For Attorneys

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    A litigation investor’s recent complaint claiming a New York mass torts lawyer effectively ran a Ponzi scheme illustrates how litigation funding arrangements can subject attorneys to legal ethics dilemmas and potential liability, so engagement letters must have very clear terms, says Matthew Feinberg at Goldberg Segalla.

  • E-Discovery Quarterly: Recent Rulings On Dynamic Databases

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    Several recent federal court decisions illustrate how parties continue to grapple with the discovery of data in dynamic databases, so counsel involved in these disputes must consider how structured data should be produced consistent with the requirements of the Federal Rules of Civil Procedure, say attorneys at Sidley.

  • Defeating Estoppel-Based Claims In Legal Malpractice Actions

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    State supreme court cases from recent years have addressed whether positions taken by attorneys in an underlying lawsuit can be used against them in a subsequent legal malpractice action, providing a foundation to defeat ex-clients’ estoppel claims, says Christopher Blazejewski at Sherin and Lodgen.

  • The Biz Court Digest: How It Works In Massachusetts

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    Since its founding in 2000, the Massachusetts Business Litigation Session's expertise, procedural flexibility and litigant-friendly case management practices have contributed to the development of a robust body of commercial jurisprudence, say James Donnelly at Mirick O’Connell, Felicia Ellsworth at WilmerHale and Lisa Wood at Foley Hoag.

  • Why Appellees Should Write Their Answering Brief First

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    Though counterintuitive, appellees should consider writing their answering briefs before they’ve ever seen their opponent’s opening brief, as this practice confers numerous benefits related to argument structure, time pressures and workflow, says Joshua Sohn at the U.S. Department of Justice.

  • Attys Beware: Generative AI Can Also Hallucinate Metadata

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    In addition to the well-known problem of AI-generated hallucinations in legal documents, AI tools can also hallucinate metadata — threatening the integrity of discovery, the reliability of evidence and the ability to definitively identify the provenance of electronic documents, say attorneys at Law & Forensics.

  • When Atty Ethics Violations Give Rise To Causes Of Action

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    Though the Model Rules of Professional Conduct make clear that a violation of the rules does not automatically create a cause of action, attorneys should beware of a few scenarios in which they could face lawsuits for ethical lapses, says Brian Faughnan at Faughnan Law.

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