International

  • November 21, 2025

    Trump Excludes Some Brazilian Foods From Higher Tariffs

    President Donald Trump has excluded many Brazilian food products from a 40% tariff, including coffee, cocoa, beef and fruits, after receiving word initial progress has been made in ongoing trade negotiations, according to an executive order.

  • November 21, 2025

    Key Issues Facing The IRS Amid Looming Budget Cuts

    The Internal Revenue Service is facing steep budget cuts in 2026, raising concerns about the agency's ability to handle taxpayer services and enforcement operations that are crucial for bringing in revenue and maintaining compliance with the voluntary system. Here, Law360 looks at the key areas where resource constraints are expected to hamper the IRS and what practitioners can do in response.

  • November 21, 2025

    UK Inheritance Tax Revenue Up 4% So Far In 2025

    The government collected £5.2 billion ($6.8 billion) in inheritance tax between April and October, figures published on Friday by Britain's tax authority show, extending a record-setting trend in the 2025/26 financial year.

  • November 20, 2025

    Importers Left With Uncertainty After US-China Trade Truce

    U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation.

  • November 20, 2025

    Treasury To Curtail Tax Credits For Unauthorized Immigrants

    The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday.

  • November 20, 2025

    EU Needs Unified Tax Benefits For Electricity, Experts Say

    The European Union needs a unified approach to tax benefits that would treat electricity more favorably than fossil fuels amid an impasse surrounding its overhaul to the energy taxation system, experts told the European Parliament's tax committee Thursday.

  • November 20, 2025

    FBAR Penalty Against Ex-Prof Is Constitutional, Court Says

    A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it.

  • November 20, 2025

    EU Council Approves Tax Deal Changes With 5 States

    The Council of the European Union said Thursday that it has approved updates to tax agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland, including new rules to help prevent tax evasion and fraud.

  • November 19, 2025

    Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real

    A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.

  • November 19, 2025

    Tax Court Upholds Rejection Of Tax Tipster's Award

    The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday.

  • November 19, 2025

    Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty

    Governments expressed widespread support for adopting measures to strengthen the mutual agreement procedure within a protocol on dispute resolution in the United Nations tax convention during the latest round of negotiations.

  • November 19, 2025

    Tax Court Substance Ruling Offers Silver Lining For Taxpayers

    Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions.

  • November 19, 2025

    OECD Releases Model Tax Treaty Updates For Amount B

    The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B.

  • November 19, 2025

    EU Tax Compliance Rules Raise €6.8B Annually, EC Finds

    The European Union's directive for administrative cooperation in taxation, known as DAC, has helped tax authorities generate €6.8 billion ($7.8 billion) a year in extra revenue, the European Commission said in a report Wednesday.

  • November 19, 2025

    Trump's Global Tariffs Curtailed Trade, Data Shows

    U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.

  • November 18, 2025

    Korea Wins Annulment Of $216M Lone Star Funds Award

    South Korea on Tuesday prevailed in its bid to wipe out a $216 million arbitral award issued to an affiliate of Lone Star Funds, though the private equity firm has already vowed to resubmit its claim to a new tribunal.

  • November 18, 2025

    Malawi Reiterates Bid For Gem Export Tax Investigation

    Malawi has bolstered its bid for a Washington federal judge to reconsider his decision barring the country from pursing discovery against a gemstone company that partnered with a mining outfit the country claims dodged billions of dollars in taxes and export royalties.

  • November 18, 2025

    French Inheritance Tax Break Grew To €5.5B, Auditor Finds

    The French government's inheritance tax break for family-owned businesses needs to be overhauled as the cost surged to more than €5.5 billion ($6.4 billion) last year, the state auditor said Tuesday.

  • November 18, 2025

    Tax Return Preparer Gets 18 Months For $25 Million Fraud

    A California tax return preparer who admitted he participated in a scheme that claimed $25 million in false refunds was sentenced to 18 months in prison by a California federal court, the U.S. Department of Justice said.

  • November 18, 2025

    Checklist Could Help Simplify Global Tax Policy, OECD Says

    A checklist of questions for global tax policymakers could help simplify the outcomes of their work, the OECD said in a Tuesday report to the Group of 20 nations.

  • November 17, 2025

    Judge Questions Eaton's Role In Lowered Credit Rating

    Tax Court Judge Albert Lauber questioned an expert for Eaton on Monday about how he arrived at a lowered credit rating for the U.S. company in a report he prepared in January 2013, shortly after it acquired an Irish-based global electrical products manufacturer and inverted.

  • November 17, 2025

    Ex-Russian Gas CFO Resentenced To 6 Years For Tax Crimes

    A Florida federal judge handed a nearly six-year prison term to a Russian gas company's former chief financial officer, who was convicted for tax evasion after the Eleventh Circuit vacated a prior sentence earlier this year.

  • November 17, 2025

    Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free

    A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International Trade's decision in a decade-old dispute.

  • November 17, 2025

    OMB Reviewing Treasury Regs On OECD Crypto Reporting

    The Office of Management and Budget is reviewing regulations proposed by the U.S. Department of the Treasury to implement automatic exchanges of information between tax authorities regarding taxpayers' cryptocurrency holdings under the OECD's crypto-asset reporting framework.

  • November 17, 2025

    MVP: Sullivan & Cromwell's Isaac Wheeler

    Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Tishman Speyer on its $3.5 billion refinancing of Rockefeller Center, earning him a spot as one of the 2025 Law360 Tax MVPs.

Expert Analysis

  • Law School's Missed Lessons: Educating Your Community

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    Nearly two decades prosecuting scammers and elder fraud taught me that proactively educating the public about the risks they face and the rights they possess is essential to building trust within our communities, empowering otherwise vulnerable citizens and preventing wrongdoers from gaining a foothold, says Roger Handberg at GrayRobinson.

  • 5 Crisis Lawyering Skills For An Age Of Uncertainty

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    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.

  • It's Time For The Judiciary To Fix Its Cybersecurity Problem

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    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.

  • Rules Of Origin Revamp May Be Next Big Trade Development

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    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.

  • SDNY OpenAI Order Clarifies Preservation Standards For AI

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    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.

  • High Court, Not A Single Justice, Should Decide On Recusal

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    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.

  • Adapting To Private Practice: 3 Tips On Finding The Right Job

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    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.

  • Painting Makes Me A Better Lawyer

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    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.

  • Protecting Sensitive Court Filings After Recent Cyber Breach

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    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.

  • What Ethics Rules Say On Atty Discipline For Online Speech

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    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.

  • 2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers

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    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.

  • Junior Attys Must Beware Of 5 Common Legal Brief Mistakes

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    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.

  • Power To The Paralegals: How And Why Training Must Evolve

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    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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