International
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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December 16, 2025
Developing Nations Expand Corporate Tax Breaks, OECD Says
Low- and middle-income countries generally expanded corporate tax incentives in 2024, while some coupled those measures with tax increases, the OECD reported Tuesday.
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December 16, 2025
Fired Top Antitrust Official Warns Of 'Politicization'
The former No. 2 at the U.S. Department of Justice's Antitrust Division until he was terminated this year testified Tuesday about the "politicization" of antitrust enforcement.
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December 17, 2025
CORRECTED: Trade Court Nixes Injunction In Trump Tariff Suit
The U.S. Court of International Trade has denied a preliminary injunction in a suit challenging President Donald Trump's emergency tariffs after auto part retailers failed to convince the court that the relief was necessary to preserve their potential right to refunds.
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December 16, 2025
Morrisons Owes £17M VAT On Chicken Sales, Tribunal Rules
A London tribunal ruled that WM Morrison Supermarkets should have paid £17 million ($22.8 million) value-added tax on rotisserie chickens because the product qualifies as "hot food."
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December 23, 2025
Sullivan & Cromwell Hires Kirkland Pair For London Office
Sullivan & Cromwell LLP said Tuesday that it has hired two new partners from Kirkland & Ellis LLP in London, boosting the firm's private equity and tax capabilities as it continues to expand in the City.
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December 15, 2025
UK Trader Couldn't Have Known Of VAT Fraud, Court Says
Despite its "cavalier approach to due diligence," a scrap metal trader in the U.K. couldn't have known its suppliers were engaged in value-added tax fraud, so it isn't liable for additional tax and penalties, the First-tier Tribunal Tax Chamber said in a decision.
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December 15, 2025
UAE Clarifies Corp. Tax Liability Calculations
The United Arab Emirates has amended its corporate tax law to clarify certain tax liability calculations, including how to factor in credits for withholding and foreign taxes, Abu Dhabi's state news agency said Monday.
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December 15, 2025
Cash Withdrawn From Online Biz Taxable, Tax Court Finds
A man who received no paycheck from the online electronics business he ran in 2012 and 2013 but used its funds to purchase luxury vehicles and help a friend should have reported those amounts as taxable income, the U.S. Tax Court held Monday.
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December 15, 2025
Fed. Court Asked To Block IRS' Microcaptive Reporting Rule
A Texas federal court should vacate an IRS rule aimed at flagging potential tax avoidance by requiring companies to disclose information about their microcaptive insurance transactions because it undermines Congress' authority, according to a Texas plastics company and its microcaptive adviser.
Expert Analysis
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Adapting To Private Practice: From Va. AUSA To Mid-Law
Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.
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7 Document Review Concepts New Attorneys Need To Know
For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.
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Agentic AI Puts A New Twist On Attorney Ethics Obligations
As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.
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Opportunity Zone's Future Corp. Tax Benefits Still Uncertain
Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.
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How GILTI Reform Affects M&A Golden Parachute Planning
Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.
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Demystifying The Civil Procedure Rules Amendment Process
Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.
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Parenting Skills That Can Help Lawyers Thrive Professionally
As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.
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Trump Tax Law's Most Impactful Energy Changes
The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.
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Adapting To Private Practice: From Texas AUSA To BigLaw
As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.
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Advice For 1st-Gen Lawyers Entering The Legal Profession
Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.
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Trump Tax Law's Most Impactful Corp. And Individual Changes
The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.
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From Clerkship To Law Firm: 5 Transition Tips For Associates
Excerpt from Practical Guidance
Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.