International
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October 30, 2026
Canada Tax Court Largely Lets PE Fund Shield EY Docs
A private equity fund can mostly use attorney-client privilege to shield documents concerning its tax strategy that were created by EY for the fund's law firm, the Tax Court of Canada said in a fight over whether an anti-avoidance rule applies to the fund's financing.
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October 29, 2026
Treasury Asked To Narrow Crackdown On Fund Strategies
The U.S. Treasury Department should develop targeted rules distinguishing abusive transactions from long-standing investment management practices in new enforcement that scrutinizes novel strategies exploiting the tax benefits of certain investment vehicles and financial products, firms and organizations told the department.
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October 29, 2026
German Co. Says $1.2M IRS Tax Bill Rests On Invalid Rule
A German manufacturer challenging a $1.2 million tax bill stemming from late information filings with the IRS told the U.S. Tax Court it should be able to claim deductions and credits despite missing the statutory due date, saying the agency applied a rule that is procedurally invalid under federal law.
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October 29, 2026
US Expatriations In Q3 Down 16% From Last Year, IRS Says
The number of people who lost or renounced their U.S. citizenship totaled more than 1,300 in the third quarter of 2026 as logged by the U.S. Department of the Treasury, down about 16% year over year and 25% from the previous quarter, the IRS said Thursday.
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October 29, 2026
Frasers Unit Loses £5.6M VAT Dispute Over Marketing Photos
A Frasers Group unit lost its bid to overturn assessments that it owed value-added tax of £5.6 million ($7.4 million) when a London court ruled that the company's marketing photos were linked to taxable retail sales and consumer credit.
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October 29, 2026
Tax Consultancy Asks 5th Circ. To Kill Microcaptive Rule
The IRS never published data showing that microcaptive transactions pose a potential for tax avoidance to justify a rule making companies and advisers report them as "transactions of interest," a tax consultancy seeking the rule's demise told the Fifth Circuit.
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October 29, 2026
Wyo. Court Flags AI Use In Defamation Case Against Tax Atty
A Wyoming federal judge threatened sanctions against an exiled U.K. financial services provider who is suing a tax attorney for defamation, noting the businessman's filings indicate the use of artificial intelligence and potential perjury regarding his residency status.
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October 29, 2026
FCA Urged To Probe Possible Leak Of Bank-Tax Budget Plans
The parliamentary Treasury Committee asked HM Treasury and the Financial Conduct Authority on Thursday to investigate whether confidential details of the government's planned bank tax increase were improperly disclosed before the Budget speech on Wednesday.
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October 28, 2026
Canada Court Won't Block Plan To Pull Group's Charity Status
A Canadian appeals court denied an organization's request to halt revenue collectors' plan to revoke its charitable status, holding that the group failed to show it would suffer irreparable harm if the agency publicly disclosed the revocation.
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October 28, 2026
Pitney Bowes Denied Interest In Repatriation Tax Fight
The IRS doesn't owe interest to Pitney Bowes for overpaid 2017 federal income taxes, the U.S. Court of Federal Claims held, finding the agency was allowed to apply a chunk of the overpayment to the global shipping and logistics company's repatriation tax liability.
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October 28, 2026
Texas Instruments Asks Court To Reject IRS Stance On FDII
The IRS' reduction of Texas Instruments' deduction for foreign-derived intangible income contradicted a long-standing interpretation by courts, which have required a connection between expenses and gross income for which a deduction is allowed, the company told the U.S. Tax Court.
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October 28, 2026
Microsoft Seeks $115M NJ Refund Over GILTI Apportionment
New Jersey unconstitutionally apportioned Microsoft's global intangible low-taxed income by failing to account for the activities of foreign entities that generated those earnings, the company argued in asking the state tax court to award it a $114.6 million corporate tax refund.
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October 28, 2026
UK Director Owes Tax On Shuffled Debt, Tribunal Affirms
The moving of a roughly £513,000 ($684,000) loan a U.K. director owed his company to its parent holding company still counts as a release of the loan, a London court affirmed Wednesday, sticking the director with an additional £195,000 in income tax.
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October 28, 2026
Exec Can't Shake AU$17M Tax Settlement, Court Says
A director cannot appeal his liability for judgment under a roughly AU$17 million ($12 million) settlement deed linked to tax fraud allegations against his companies because his challenge had no merit, was filed late and lacked supporting evidence, the Supreme Court of New South Wales said Wednesday.
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October 28, 2026
ABA Urges Treasury To Drop 1040 Citizenship Question
The American Bar Association's Tax Section urged the U.S. Department of the Treasury to remove a proposed citizenship status question from individual tax returns, saying it has no stated purpose and is not connected to any tax-related eligibility determination.
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October 28, 2026
Judge Sides With Feds In Pair's $1.6M Tax Penalty Dispute
A formerly married couple are not entitled to claim a refund of roughly $1.6 million for tax penalties related to a foreign trust, a Pennsylvania federal magistrate judge ruled, finding the court lacks jurisdiction because they failed to demonstrate they properly filed a refund claim.
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October 28, 2026
CBP Clears Nearly 16M Imports In 3rd Tariff Refund Phase
In just over two weeks, U.S. Customs and Border Protection has cleared nearly 16 million more imports as part of the third phase of its tariff refund system, according to a declaration filed by a CBP official at the U.S. Court of International Trade.
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October 28, 2026
Nigerian Man Extradited For $100 Million IRS Refund Scheme
A Nigerian man facing charges that he obtained more than $100 million in tax refunds fraudulently by posing as tax professionals and taxpayers was arraigned after being extradited from Benin, the U.S. Department of Justice said.
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October 28, 2026
Pillar 2 Minimum Tax Funds Could Finance EU Budget
A coming draft of the European Union's next long-term budget could propose using Pillar Two funds as a revenue source to finance the bloc's spending priorities, three EU officials told Law360 on Wednesday.
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October 28, 2026
Healey Looks To Simplify But Not Abolish Shareholder Taxes
Chancellor John Healey told MPs on Wednesday that the government would retain stamp duty on share trading but pledged to modernize the tax, drawing criticism of a "missed opportunity" to revive interest in the London Stock Exchange.
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October 28, 2026
UK Gov't To Temporarily Raise Bank Surcharge To 6%
The U.K.'s Labour government will temporarily raise the bank surcharge to 6% to help generate more revenue to cover its expanded spending plans, Chancellor John Healey said in his autumn Budget on Wednesday.
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October 28, 2026
Businesses Warn EU Against Diluting Tax Simplification Bill
More than 20 industry associations warned European Union countries Wednesday against diluting draft proposals to simplify tax regulation.
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October 28, 2026
Gov't Tweaks UK Tax Allowance To Protect Pensioners
The government announced plans on Wednesday to protect pensioners from paying income tax on the state pension, which is set to rise above the basic income tax threshold.
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October 27, 2026
IRS Asks 1st Circ. To Toss Shuttered Bank Owner's Claims
The IRS asked the First Circuit to dismiss unlawful property seizure and due process claims against former IRS Criminal Investigation officers in a dispute related to a shuttered online bank suspected of facilitating tax evasion and money laundering, saying the bank's former owner failed to establish plausible allegations.
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October 27, 2026
Medtronic, IRS Unable To Settle Transfer Pricing Case
Medtronic and the IRS were unable to settle their dispute over how to price intangibles that the medical device maker licensed to a Puerto Rican affiliate, the parties told the U.S. Tax Court, potentially teeing up a third trial.
Expert Analysis
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Choral Singing Makes Me A Better Lawyer
Singing in the New York City Bar Chorus — a hobby partly inspired by the late U.S. District Judge Richard Owen, who infused my clerkship year with opera music — has improved my legal career by refining my abilities to listen, exude confidence and develop emotional intelligence, says Bonnie Baker at Friedman Kaplan.
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Power To The Paralegals: Burnout As A Structural Problem
Law firm leadership can best retain their paralegals not by encouraging self-care, but by seeking top-down structural solutions for the quiet proliferation of responsibilities and the vicarious exposure to client trauma that particularly drive burnout in this vital role, says Erika Sneeringer at Brockstedt Mandalas.
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Managing Post-IEEPA Tariff Refunds, Replacements And Risks
Companies and investors reeling from the rapid changes resulting from February's U.S. Supreme Court ruling that the International Emergency Economic Powers Act doesn't authorize tariffs should focus on understanding the duty refund process, the likely replacement tariffs and the operational ways they can minimize their tariff exposure, say attorneys at Debevoise.
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Economic Questions To Ask Amid Tariff Refund Class Actions
The U.S. Supreme Court's recent holding that the International Emergency Economic Powers Act doesn't authorize the president to impose tariffs has sparked class actions, but determining whether a retailer received a windfall is complex, even if it passed tariff costs into consumer prices before receiving a refund, say economists at Ankura Consulting Group.
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Cow Horse Makes Me A Better Lawyer
Moving an unwilling 800-pound cow while riding a horse at high speed is exhilarating, a little unhinged and, at least for me, a surprisingly effective training ground for litigation — both demand focus, preparation over rigid planning and the willingness to act despite fear, says Ashley Zitrin at Glenn Agre.
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Checking For AI Errors Is Now A Two-Way Street
A handful of recent federal and state cases demonstrate the importance of checking for errors generated by artificial intelligence not only in your own court submissions, but also your opponent's, as well as when catching opposing counsel's AI mistakes could result in an award for attorney fees, says Tamara Barago at Hollingsworth.
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5 Things Associates Must Ask About Their Firm's Merger Plan
The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.
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2 'Rocket Dockets' And The Rules That Propel Them
The fastest civil trial courts in the country are currently in the Eastern District of Virginia and the Southern District of Florida, and their chief judges provide insights into the court rules that keep them ahead, says Robert Tata at Hunton.
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Your Next Litigation Hold Should Cover AI Chat Logs
The Delaware Chancery Court’s recent decision in Fortis Advisors v. Krafton to treat a CEO’s artificial intelligence chats as substantive evidence is being read as a discovery warning to litigators, but there is a second duty-to-preserve lesson that is especially pertinent to in-house counsel, say attorneys at Faegre Drinker.
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Studying Foreign Languages Makes Me A Better Lawyer
Studying Italian and Japanese has shown me that learning a new language can benefit a legal career in several ways, including by demonstrating the importance of approaching problems from a fresh perspective and the value of practicing patience with colleagues and clients, says Anna King at Genworth Financial.
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Sold Inventory May Drive Tax Treatment Of Tariff Refunds
Companies determining the tax treatment of refunds expected following the U.S. Supreme Court's February decision invalidating tariffs imposed under the International Emergency Economic Powers Act should consider whether the tariff costs have already reduced their income considering the cost of goods sold, say attorneys at McDermott.
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Adapting To AI-Driven Scrutiny Of Foreign Asset Disclosures
As the government expands AI-driven, cross-agency fraud detection, foreign asset disclosure should be viewed as part of a broader, data‑driven enforcement ecosystem that prioritizes consistency, documentation and proactive governance, says Logan Koehring at FBT Gibbons.
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Tax Teams Get No Bright-Line Rule From AI Privilege Cases
Three recent appellate decisions that considered artificial intelligence in the context of attorney-client privilege protections illustrate that taxpayers and tax practitioners alike must consider the pertinent facts on a case-by-case basis, with particular attention to confidentiality, disclosure risk and system design, say attorneys at Morgan Lewis.