International

  • December 22, 2025

    10th Circ. Tosses Plumbing Co.'s Captive Deduction Bid

    The Tenth Circuit is not the proper forum for a Utah plumbing company to challenge the Internal Revenue Service's 2016 notice denying a microcaptive insurance deduction, the appeals court found Monday, citing two statutes that bar the company's arguments.

  • December 22, 2025

    Draft House Bill Would Clarify Tax Rules For Digital Assets

    A bipartisan draft bill in the U.S. House would modernize the federal tax code for digital assets, its backers said, by establishing a "commonsense tax treatment" for regulated payment stablecoins, clarifying source-of-income rules for trading and extending existing securities-lending rules to digital assets.

  • December 22, 2025

    Top Federal Tax Policies Of 2025

    The first year of President Donald Trump's second term brought the passage of this summer's budget reconciliation bill, which renewed major parts of the 2017 Tax Cuts and Jobs Act, and major staffing changes at the Internal Revenue Service. Here, Law360 looks at the most consequential developments in federal tax policy in 2025.

  • December 22, 2025

    Tariff Refunds Would Be 'A Mess,' Economic Official Says

    It would be an "administrative problem" to issue tariff refunds in the aftermath of a potential U.S. Supreme Court ruling against the White House's trade measures, a top economic policy official said.

  • December 22, 2025

    IRS Seeks Input On Updates To Voluntary Disclosure Process

    The Internal Revenue Service asked Monday for comments on a proposed change to its voluntary disclosure program that would require payment of all taxes, penalties and interest within three months after being conditionally approved for the program.

  • December 19, 2025

    EU High Court Advised To Force Portugal To Reclaim Taxes

    The European Union's top court should rule that Portugal can't allow tax enforcement proceedings to be suspended in the case of unlawful state aid granted by the Madeira Free Zone, an adviser to the court said.

  • December 19, 2025

    Trade Court Remands Canada Lumber Duty Calculation Again

    The U.S. Commerce Department again failed to sufficiently justify how it calculated a subsidy rate in an antidumping duty administrative review for a Canadian exporter of softwood lumber products, the U.S. Court of International Trade said.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • Impact Of Corporate Transparency Act Ambiguity On Banks

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    Even though banks generally needn't file beneficial ownership information reports, financial institutions must continue to monitor the status of the Corporate Transparency Act and understand its requirements in case the nationwide injunction that was issued against the CTA earlier this month is overturned, say attorneys at Armstrong Teasdale.

  • 6 Changes I Would Make If I Ran A Law School

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    Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.

  • Firms Still Have The Edge In Lateral Hiring, But Buyer Beware

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    Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.

  • Think Like A Lawyer: 1 Type Of Case Complexity Stands Out

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    In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.

  • Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity

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    Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Reframing Document Review

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    For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.

  • 3 Ways To Train Junior Lawyers In 30 Minutes Or Less

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    Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.

  • The Bar Needs More Clarity On The Discovery Objection Rule

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    Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.

  • So You Want To Move Your Law Practice To Canada, Eh?

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    Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.

  • Promoting Diversity In The Selection Of ADR Neutrals

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    Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.

  • Striking A Balance Between AI Use And Attorney Well-Being

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    As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.

  • How Judiciary Can Minimize AI Risks In Secondary Sources

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    Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.

  • How Attorneys Can Break Free From Career Enmeshment

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    Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.

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