International

  • January 07, 2026

    IRS Outlines Process For PFICs Seeking Retroactive Elections

    The Internal Revenue Service set out requirements Wednesday for passive foreign investment corporations seeking rulings to allow them to make retroactive qualified electing fund elections.

  • January 06, 2026

    IRS Appeals Pause Of ICE Info-Sharing Agreement

    The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.

  • January 06, 2026

    Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules

    A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasion that would justify the regulations.  

  • January 06, 2026

    Thai Cabinet OKs Changes To Aid Satisfying Global Min. Tax

    Thailand's Cabinet has approved draft legislation aimed at helping companies comply with the 15% global minimum tax, the country's tax authority said.

  • January 06, 2026

    Uber Changes UK Contracts Over New Minicab VAT Rules

    Uber has changed its contracts with its British drivers to reclassify itself as an agent, a move that will save it from collecting value-added tax on fares, just before the U.K.'s overhaul of tax rules for the minicab sector took effect.

  • January 06, 2026

    Ireland Offers Europe's First Tax Break For Unscripted Shows

    Ireland is offering a corporate tax credit for unscripted productions that promote Irish and European culture, the Department of Finance said, noting that the initiative is the first of its kind in Europe.

  • January 06, 2026

    Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team

    After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on the tax elements of mergers and acquisitions.

  • January 05, 2026

    Md. Railway Distributor Exec Sued Over Alleged Asset Looting

    Chinese railway equipment manufacturer Anyang Railway Equipment Co. Ltd. has filed suit in Maryland federal court, claiming the sole executive and majority shareholder of a railway distribution company, in which Anyang is also a shareholder, looted corporate assets for personal gain and excluded Anyang from management decisions, among other things.

  • January 05, 2026

    EU Sets Default Emission Levels For Carbon Border Tax

    The European Union released default levels of greenhouse gas emissions that importers must use to calculate liabilities for the newly enforced carbon border adjustment mechanism when they lack reliable information on the emissions associated with producing covered products.

  • January 05, 2026

    Countries Reach Deal To Exempt US From Pillar 2 Tax

    Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.

  • January 05, 2026

    ECJ To Mull Parent-Subsidiary Directive's Tax Impact

    The European Union's top court will rule on the tax implications of the EU's parent-subsidiary directive for a loss-making company in Germany following a request from the country's finance court, according to a Monday notice.

  • January 05, 2026

    Gibson Dunn Adds Sidley Tax Pro In Silicon Valley

    Gibson Dunn & Crutcher LLP announced Monday that it has bulked up its tax practice group with a partner in Palo Alto, California, who previously co-led the global tax practice and headed up the West Coast tax group at Sidley Austin LLP.

  • January 02, 2026

    Busy DOJ Tax Atty Seeks More Time In 7th Circ. AbbVie Case

    A U.S. Department of Justice tax attorney asked the Seventh Circuit on Friday for another extension to file an opening brief in a dispute over AbbVie's $1.6 billion payment to an Irish biotechnology company, citing staffing shortages and internal procedural requirements.

  • January 02, 2026

    IRS Floats Updates To Fee Paid By Brand Drugmakers

    The Internal Revenue Service floated updates to regulations governing how branded prescription drug manufacturers or importers should calculate an annual fee established by the Affordable Care Act, a move the agency said aims to incorporate changes in drug discount programs and clarify tax reporting.

  • January 02, 2026

    Federal Tax Policy To Watch In 2026

    Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.

  • January 02, 2026

    Top Federal Tax Cases To Watch In 2026

    The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.

  • January 02, 2026

    European Tax Policy To Watch In 2026

    The European Union may have to take a more independent line on international tax in 2026 as it tackles policies such as the minimum corporate tax, but its success will likely depend on how it deals with opposition to such policies from the U.S. administration. Here, Law360 looks at important European tax developments to watch for the coming year.

  • January 02, 2026

    Top International Tax Policy To Watch In 2026

    The details of a proposed U.S. exemption from the global minimum tax's international provisions, possible retaliatory measures by the U.S. government and the rollout of major changes in Congress' latest budget are high priority for tax professionals going into 2026. Here, Law360 previews international tax practitioners' top priorities for the coming year.

  • January 02, 2026

    Top International Tax Cases To Watch In 2026

    Major multinational corporations such as McKesson and Coca-Cola will continue to litigate high-stakes international tax cases in 2026, including transfer pricing disputes with billions of dollars on the line and fights over whether regulations exceed the government's authority. Here, Law360 looks at four key international tax cases to follow in the new year.

  • January 01, 2026

    Blue Slip Fight Looms Over Trump's 2026 Judicial Outlook

    In 2025, President Donald Trump put 20 district and six circuit judges on the federal bench. In the year ahead, a fight over home state senators' ability to block district court picks could make it more difficult for him to match that record.

  • January 01, 2026

    4 High Court Cases To Watch This Spring

    The U.S. Supreme Court justices will return from the winter holidays to tackle several constitutional disputes that range from who is entitled to birthright citizenship to whether transgender individuals are entitled to heightened levels of protection from discrimination. 

  • January 01, 2026

    BigLaw Leaders Tackle Growth, AI, Remote Work In New Year

    Rapid business growth, cultural changes caused by remote work and generative AI are creating challenges and opportunities for law firm leaders going into the New Year. Here, seven top firm leaders share what’s running through their minds as they lie awake at night.

  • December 23, 2025

    Tax Court Denies Couple's Child Tax Credit For Nephew

    A couple who jointly filed as a married couple in 2020 cannot claim the child tax credit for a minor whom they describe as their nephew from Mexico who came to live with them that year, a U.S. Tax Court judge ruled Tuesday.

  • December 23, 2025

    Top International Trade Developments Of 2025

    Importers faced novel levels of uncertainty in 2025 as President Donald Trump introduced several new tariff actions during his second term, including some that prompted importers to challenge a law used to authorize duties that had never been used before. Here, Law360 examines the year's top international trade developments.

  • December 23, 2025

    Top Federal Tax Decisions Of 2025

    Over the past year, federal courts have issued decisions that extended the deadline for challenging tax bills in the U.S. Tax Court, allowed the IRS to pursue a woman's decades-old tax debt caused by her return preparer and lifted a $1 million reporting penalty because a jury didn't sign off. Here, Law360 reviews some of the most significant federal tax decisions of 2025.

Expert Analysis

  • Adapting To Private Practice: From DOJ Leadership To BigLaw

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    The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.

  • How The CRE Industry Is Adapting To Tariff Uncertainty

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    Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.

  • Law Firm Executive Orders Create A Legal Ethics Minefield

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    Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.

  • Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike

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    The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.

  • Firms Must Embrace Alternative Billing Models Or Fall Behind

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    As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.

  • How Attorneys Can Master The Art Of On-Camera Presence

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    As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.

  • Firms Still Have Lateral Market Advantage, But Risks Persist

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    Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • We Must Allow Judges To Use Their Independent Judgment

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    As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.

  • Preparing For Tariffs On Canadian Power In The Northeast

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    The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.

  • Making The Case For Rest In The Legal Profession

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    For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.

  • Mitigating Tariff Risks For Healthcare In US And Canada

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    Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.

  • 4 Ways Women Attorneys Can Build A Legal Legacy

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    This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.

  • A Judge's Pointers For Adding Spice To Dry Legal Writing

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    U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.

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