International
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February 18, 2026
Varian Contests $1.5B IRS Bill In Tax Court
Varian Medical Systems does not owe $1.24 billion in additional taxes or $248 million in penalties the IRS assessed after the agency recharacterized the company's sales of subsidiaries in the Netherlands and Switzerland, the company told the U.S. Tax Court.
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February 18, 2026
IRS Asks Court To Deny Probe Of Improper ICE Data-Sharing
A coalition suing the IRS over its data-sharing deal with immigration enforcement authorities should not be allowed to investigate the agency's revelation that it shared some data improperly, the IRS told a D.C. federal court, saying it made the admission "in good faith."
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February 18, 2026
Glencore Says It Paid $1B To HMRC Over Tax Disputes
Mining giant Glencore told shareholders Wednesday that it paid $1 billion to the U.K.'s tax authority last year over tax disputes but is pushing to recover some of the money.
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February 18, 2026
Tax Group Of The Year: Eversheds Sutherland
Eversheds Sutherland's tax practice advised on key deals in 2025, guiding Duke Energy in securing $20 million in investment credits and aiding Verizon in avoiding $12 million in corporate franchise taxes, earning it a spot among the 2025 Law360 Tax Groups of the Year.
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February 18, 2026
8th Circ. Misread Law In 3M's $24M Case, Tax Prof Says
The Eighth Circuit misconstrued the statute underpinning transfer pricing regulations when it blocked the IRS from allocating nearly $24 million of 3M Co.'s Brazilian income, a tax professor said in backing the agency's bid for a rehearing by the full court.
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February 18, 2026
Australia Seeks Input On Global Minimum Tax Amendments
Australia is looking for input on changes to its global minimum tax legislation aimed at implementing Organization for Economic Cooperation and Development guidance, including tweaks to how its domestic minimum tax applies to stateless entities and joint ventures, the Department of the Treasury said.
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February 17, 2026
No Fraud By IRS In FOIA Over $18M Tax Case, DC Circ. Says
The Internal Revenue Service did not commit fraud when it said records were missing amid Freedom of Information Act litigation related to an $18 million tax case, the D.C. Circuit said Tuesday, denying claims made by the estate of a man whose offshore businesses were raided.
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February 17, 2026
Ex-IRS Official Drops Suit Over Private Info Leak
The former commissioner of the IRS' Large Business and International Division asked a D.C. federal court to drop her suit accusing the agency of unlawfully leaking information on her employment status to the media, according to a filing.
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February 17, 2026
UK Court Blocks Telecom's £51M VAT Refund Bid
A London appeals court dismissed a U.K. telecommunications provider's bid to recover £51.1 million ($69.3 million) in value-added tax payments, agreeing with a lower court's conclusion that VAT is owed when phone plans are sold, not when they're used.
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February 17, 2026
OECD Updates Tool For Amount B And Issues Guidance
The Organization for Economic Cooperation and Development released an updated tool Tuesday for making calculations under its transfer pricing method known as Amount B and issued guidance on frequently asked questions.
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February 17, 2026
EU Seeks Feedback For Bill To Streamline Corporate Tax Laws
The European Union is seeking feedback on how to streamline its corporate tax laws in a bill slated to be proposed in the second quarter of the year, the bloc's executive branch said.
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February 17, 2026
Ireland Looks At Expanding Coverage Of R&D Tax Credit
Ireland is looking at expanding the coverage of its research and development tax credit, including by revising qualifying expenditures, subcontracting rules and capital expenditures, according to a report by the country's finance ministry.
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February 17, 2026
Unregistered Tax Advisers May Be Blocked, HMRC Warns
HM Revenue & Customs may block intermediaries who fail to register as a tax adviser, including for corporate and personal tax matters, cutting them off from services, the tax authority said Tuesday.
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February 17, 2026
Sweden Proposes New Tools To Combat VAT Fraud
Swedish lawmakers are mulling legislation that would target value-added tax fraud through a series of new measures, including enabling tax officials to deny VAT registration if they see red flags, Sweden's Finance Ministry announced Tuesday.
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February 17, 2026
EU Blacklists Turks and Caicos, Vietnam As Tax Havens
The European Union blacklisted two countries as tax havens Tuesday over their failure to meet transparency standards and policies encouraging foreign companies and entities to shift their profits overseas.
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February 13, 2026
Senate Dems Say IRS-ICE Privacy Warnings Proved Correct
The Internal Revenue Service's recent admission that a faulty system improperly shared taxpayer records with U.S. Immigration and Customs Enforcement vindicates long-standing warnings about privacy and data protection risks, Senate Democrats said.
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February 13, 2026
Gov'ts To Explore Transfer Pricing Database For UN Tax Pact
Governments are expected to form a task force on improving access to transfer pricing information, including by potentially creating a database, to support the dispute protocol under the United Nations framework convention on international tax cooperation, according to negotiations on the protocol held Friday.
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February 13, 2026
FinCEN Eases Beneficial Owner ID Rules For Banks
The U.S. Treasury Department's Financial Crimes Enforcement Network announced Friday that banks are excepted from certain aspects of the agency's customer due diligence rules, including the requirement to repeatedly identify the beneficial owners of existing corporate account holders.
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February 13, 2026
Fuel Credit Regs Clear Clouds Over Middleman Sales
The U.S. Treasury Department's move to allow domestic clean fuel producers selling to intermediaries to qualify for the production tax credit under newly released proposed rules recognizes the industry's commercial realities and clears up uncertainty that had been hindering the market, practitioners said.
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February 13, 2026
Taxation With Representation: Homburger, Lenz & Staehelin
In this week's Taxation With Representation, offshore drilling contractor Transocean Ltd. acquires rival Valaris Ltd., historic British fund manager Schroders agrees to a cash takeover by U.S. asset manager Nuveen, and a consortium that includes U.S. private equity firm Advent International LP and FedEx Corp. buy Polish parcel locker company InPost.
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February 13, 2026
Blair's Think Tank Urges UK Gov't To End Energy Windfall Tax
The U.K.'s Labour government must phase out the windfall tax on the energy industry and lift the ban on new oil and gas drilling licenses in the North Sea to increase revenue long term, the Tony Blair Institute said Friday.
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February 12, 2026
IRS Guidance Offers Relief In Energy Credits' Sourcing Limits
The IRS issued interim guidance Thursday providing two safe harbor options for clean energy facilities or manufacturers of energy components to determine the extent to which they received material assistance from an entity tied to a foreign government that the U.S. deems adversarial.
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February 12, 2026
Gov'ts Favor Optionality In UN Tax Treaty's Dispute Protocol
Governments widely supported having the ability to choose between options for dispute resolution and prevention while making an opt-out unavailable for some methods in the dispute protocol under the United Nations framework convention on international tax cooperation, according to negotiations on the protocol.
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February 12, 2026
Canadian Living In Wash. Says FBAR Penalty Required Jury
A Canadian man living in the U.S. was unconstitutionally fined more than $700,000 for failing to report his foreign bank accounts, he told a Washington federal court, arguing that the amount is excessive and that its assessment violates his right to a jury trial.
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February 12, 2026
Hotel Cos. Urge UK Gov't To Abandon Holiday Tax Proposal
The Labour government should not introduce what is known as a holiday tax on the hospitality industry, more than 200 hotel companies told the U.K.'s finance minister.
Expert Analysis
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Power To The Paralegals: How And Why Training Must Evolve
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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5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.
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Evaluating The Current State Of Trump's Tariff Deals
As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.
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How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.
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Preserving Refunds As Tariffs Await Supreme Court Weigh-In
In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.
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Writing Musicals Makes Me A Better Lawyer
My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.
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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.