International

  • April 09, 2026

    IRS Urged To Clarify Foreign-Owner Rules For Energy Credits

    Public power and nuclear associations, along with battery groups, are among stakeholders urging the Internal Revenue Service to clarify foreign ownership rules that could disqualify projects from certain clean energy tax credits, emphasizing that timely guidance is critical to securing project financing.

  • April 09, 2026

    Trade Court Shifts Tariff Refund Proceedings To New Suit

    The underlying U.S. Court of International Trade suit serving as the core of the government's development of a refund system for the now-invalidated International Emergency Economic Powers Act tariffs has changed after the original case was dismissed.

  • April 09, 2026

    Germany Lists Countries With Global Minimum Tax Laws

    Germany's Finance Ministry amended its global minimum tax legislation by adding a list of jurisdictions that have adopted qualified corresponding measures, with the amendment taking effect Thursday.

  • April 09, 2026

    UK Drafts Carbon Border Tax Rules To Match EU System

    The U.K. tax authority released draft regulations on the country's carbon border tax regime Thursday that would broadly align it with the European Union's system for taxing carbon-intensive imports.

  • April 09, 2026

    Fate Of Wealth Tax Hangs In Balance In Hungary Election

    The outcome of Hungary's parliamentary election Sunday could determine whether the country adopts a wealth tax, a proposal that feeds into wider debates in Europe around tax policy fairness and effectiveness.

  • April 09, 2026

    OECD Calls For Neutral Taxation As Growth Driver

    Lawmakers should favor neutral tax policies such as value-added tax and certain property levies if they want to boost economic growth, the Organization for Economic Cooperation and Development said in a report released Thursday. 

  • April 09, 2026

    Insurance Body Calls For Changes To EU Tax Reform Plans

    Insurance Europe has urged European Union lawmakers to give workplace pension institutions that are regulated as insurers the same fast-track dividend tax relief as other pension providers in tax reforms which are pending.

  • April 08, 2026

    Tax Court Limits Varian's Deemed Dividends Deduction

    A deduction that California-based Varian Medical Systems was allowed for deemed dividends must be reduced by the amount of its corresponding foreign tax credit, the U.S. Tax Court held Wednesday.

  • April 08, 2026

    Oil Giants Owed Far More Tax Abroad Than In US, Report Says

    Major U.S. energy companies continued to owe far more taxes abroad than domestically last year, with Exxon Mobil and Chevron each incurring less than 10% of their total liabilities from the federal government, the Financial Accountability and Corporate Transparency Coalition said in a report.

  • April 08, 2026

    Pryor Cashman Hires Tax Atty In NY From Curtis

    Pryor Cashman LLP announced Tuesday that it has hired a former Curtis Mallet-Prevost Colt & Mosle LLP partner, touting her history advising businesses on complex tax matters across jurisdictions.

  • April 08, 2026

    Jamaica Saw $7.7B In Transfer Pricing Reports, OECD Says

    Jamaica's tax authority saw a major boost in disclosures of transfer pricing transactions since overhauling its legal framework a decade ago, with transactions worth €6.6 billion ($7.7 billion) disclosed in the 2022-2023 fiscal year, the OECD said Wednesday in a report.

  • April 08, 2026

    Engineering Co. Owes £3M Contributions, UK Court Says

    A Scotland-based engineering company is on the hook for £2.9 million ($3.9 million) in national insurance contributions, according to a U.K. appeals court, which held the company couldn't avoid contributions by moving employee contracts offshore.   

  • April 08, 2026

    1 Year Later, How Tariffs Have Crept Into Real Estate Contracts

    In the year since President Donald Trump's Rose Garden announcement of sweeping worldwide tariffs last April, real estate and construction lawyers have wrestled with how duties or potential duties fit into clients' deals, and sources recently shared more than half a dozen contract examples from the past year with Law360 Real Estate Authority.

  • April 08, 2026

    UK Gov't Expands Tax Relief For Startup Investment

    The U.K.'s Labour government is expanding investment tax relief to unlock £100 million ($134.4 million) worth of funding for startups and early-stage businesses looking to grow, according to HM Treasury.

  • April 08, 2026

    Swiss Implement Guidance On Minimum Tax Safe Harbors

    Switzerland is implementing OECD guidance on the 15% global minimum tax with regards to several safe harbors, including an exemption for U.S. companies, and the treatment of deferred tax assets, according to the country's tax authority.

  • April 07, 2026

    Rivera Kept $50M Venezuela Deal Quiet, Ex-Partner Says

    The government's star witness took the stand Tuesday in the criminal case against former U.S. Rep. David Rivera of Florida, telling jurors that Rivera and others kept a $50 million consulting contract with a unit of Venezuela's state-owned oil company quiet because of concerns about how it would be perceived in Miami.

  • April 07, 2026

    Partnership Wants Tax Court To Reconsider Basis Question

    A partnership asked the U.S. Tax Court to reconsider its finding that a company contributing a promissory note for a stake in the partnership had zero basis in the note, saying basis must be determined when a note is contributed, not at its conception.

  • April 07, 2026

    UK Oil Co. Can Avoid £167M Tax Assessment, Tribunal Says

    A U.K. oil company isn't liable for a £167 million ($221 million) increase to its taxable profits because for tax purposes it shouldn't be treated as having acquired an oil-related business following an intra-group transfer, according to an Upper Tribunal decision published Tuesday.

  • April 07, 2026

    IRS Updates Foreign Housing Expense Limits For 2026

    The Internal Revenue Service released adjustments Tuesday to the limitation on foreign housing expense deductions and exclusions for 2026.

  • April 07, 2026

    HMRC Clarifies Tax Relief For Investors Moving To UK

    Individuals who moved to the U.K. in recent years have until the end of January 2028 to file for tax relief under the foreign income and capital gains regime, Britain's tax authority said in new guidance Tuesday.

  • April 07, 2026

    Floridian Says Jury Was Required Before $20M FBAR Fine

    A dual U.S.-German citizen urged a Florida federal court to reject a magistrate judge's recommendation to uphold a nearly $20 million tax judgment for undisclosed foreign bank account information, contending the judge failed to recognize a recent change in the law about access to jury trials. 

  • April 08, 2026

    CORRECTED: HMRC Takes On New Powers As Tax Dodge Measures Kick In

    HM Revenue and Customs has assumed new powers to tackle tax fraud and evasion as key parts of new legislation take effect, including tougher rules on construction industry schemes and penalties for promoters of tax avoidance arrangements. Correction: A previous version of this article misstated which HMRC reforms took effect on April 6. The error has been corrected.

  • April 06, 2026

    Chewy Investor Settles Suit Against BC Partners For $29.5M

    A Chewy Inc. investor has brokered a $29.5 million deal with BC Partners that, if finalized, would settle the investor's derivative suit that alleged BC Partners saddled Chewy investors with potential tax liabilities following a financially unfair downstream merger involving PetSmart Inc., the parties told the Delaware Chancery Court on Monday.

  • April 06, 2026

    IRS' Proposed Voluntary Disclosure Rule Could Be Dissuasive

    The IRS has proposed relaxing the 75% civil fraud penalty for participants in its voluntary disclosure program, but a corresponding 90-day deadline for complying with all payment and filing requirements could discourage some taxpayers from coming forward.

  • April 06, 2026

    Germany, Italy Ask EU For Windfall Tax On Energy Companies

    Germany, Italy, Spain, Austria and Portugal have asked the European Union to create a windfall profits tax on energy companies so governments can finance relief for spiking oil prices fueled by the U.S. and Israel's war with Iran, the EU and three finance ministries told Law360 on Monday.

Expert Analysis

  • ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'

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    The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.

  • Can Companies Add Tariffs Back To Earnings Calculations?

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    With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.

  • A Look At DOJ's Dropped Case Against Early Crypto Operator

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    The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.

  • 8 Ways Lawyers Can Protect The Rule Of Law In Their Work

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    Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.

  • Law School's Missed Lessons: Communicating With Clients

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    Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

  • Navigating Antitrust Risks When Responding To Tariffs

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    Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.

  • Key Points From HMRC's Tax Reform Proposals

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    Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • What To Note As UK Adopts OECD Crypto Disclosure Rules

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    With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

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