International
-
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.
-
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.
-
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.
-
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.
-
February 12, 2026
Dinsmore Adds IRS Senior Counsel As Tax Partner In DC
An attorney who spent more than a decade working as an attorney and reviewer at the Internal Revenue Service has joined Dinsmore & Shohl LLP's Washington, D.C., tax group, the firm announced this week.
-
February 12, 2026
Broker Says Denmark Can't Bring £56M Cum-Ex Fraud Claim
An English broker told Britain's top court on Thursday that Denmark's tax authority can't sue it for more than £56 million ($76 million) over a tax refund fraud, because an earlier decision in related proceedings rendered the claim inadmissible.
-
February 11, 2026
House OKs Ending Canada Tariffs After GOP Block Fails
The U.S. House of Representatives approved a resolution Wednesday evening that would end President Donald Trump's tariffs on Canadian imports, a day after Republican lawmakers were unable to pass a measure blocking that kind of effort.
-
February 11, 2026
Gov'ts Want Net Or Gross Option For Services In UN Tax Pact
There should be an option for taxpayers to elect gross-basis or net-basis taxation within the protocol on cross-border services under the United Nations framework convention on international tax cooperation, some governments said during negotiations on the protocol.
-
February 11, 2026
'It Takes Time To Write': Jackson On High Court's Tariff Ruling
U.S. Supreme Court Justice Ketanji Brown Jackson has provided an unusual update on the court's decision over President Donald Trump's authority to impose emergency tariffs, saying in a TV interview that the justices are still working on what is one of their most anticipated rulings this term.
-
February 11, 2026
Tax Group Of The Year: Sullivan & Cromwell
Sullivan & Cromwell LLP's tax practice showed the depth of its experience this past year, advising on multijurisdictional tax litigations to playing a key role counseling RedBird Capital Partners in a deal that merged Paramount and Skydance, helping it earn a place among the 2025 Law360 Tax Groups of the Year.
-
February 11, 2026
Tax Advisers Urge EU To Scrap Disclosure Rules
The European Union should scrap rules requiring tax advisers to disclose potentially abusive cross-border strategies as it looks to update its regime for member countries' exchange of information, a European tax advisers group said.
-
February 11, 2026
Morgan Lewis Adds 30-Year Baker McKenzie Atty, Ex-Tax Chair
The former chair of Baker McKenzie's Americas tax practice has joined Morgan Lewis & Bockius LLP's Washington, D.C., team, where he'll work as a partner on transfer pricing disputes and tax matters, the firm announced Wednesday.
-
February 11, 2026
Denmark Says Cum-Ex Ruling No Bar To £56M Fraud Claim
Denmark told Britain's top court on Wednesday that it should be allowed to sue an English brokerage for £56 million ($76 million) over a tax refund fraud, arguing that an earlier decision barring linked allegations was based on "fundamentally different" facts.
-
February 10, 2026
Gov'ts Want Varied Nexus In UN Treaty's Services Protocol
Business models should have different nexus rules that don't rely on physical presence in the protocol on cross-border services under the United Nations framework convention on international tax cooperation, governments said Tuesday.
-
February 10, 2026
DOJ Drops Bid For Offshore Asset Freeze In $28M Tax Suit
The U.S. Department of Justice and a family of overseas-trust beneficiaries struck a partial deal in a $28 million tax suit in Florida federal court, with the DOJ dropping its push to freeze the family's assets and the family agreeing to temporarily limit their account withdrawals.
-
February 10, 2026
Ex-Clifford Chance Pro Says £8M Libel Claim Is SLAPP
Legal commentator Dan Neidle asked a court on Tuesday to use new powers to throw out an £8 million ($11 million) libel claim accusing the former Clifford Chance partner of engaging in a vendetta against a barrister, arguing that the claim was launched to silence him.
-
February 09, 2026
Gov'ts Back UN Treaty's Services Protocol Covering DSTs
All income taxes and digital services taxes should be covered by the protocol on cross-border services under the United Nations framework convention on international tax cooperation, many governments said Monday during negotiations regarding the protocol.
-
February 09, 2026
DOD Employee Denies Laundering Millions For Scammers
A U.S. Department of Defense logistics specialist pled not guilty Monday to federal charges accusing him of laundering millions as part of an alleged Nigeria-based fraud scheme that targeted victims in the United States.
-
February 09, 2026
$19M In Foreign Account Penalties Required Jury, Court Told
A U.S.-German citizen who failed to report his foreign accounts to the IRS told a Florida federal court that his $19 million punishment violates his right to a jury trial under a U.S. Supreme Court ruling that curbed the use of in-house agency courts to hand down stiff penalties.
-
February 09, 2026
€306M Money Laundering Network Sting Leads To 13 Arrests
Law enforcement agencies in the European Union have arrested more than a dozen people in several raids after an investigation into a €306 million ($364.5 million) international money laundering scheme with links to drug trafficking and tax fraud.
-
February 08, 2026
DOJ Drops Challenge To AbbVie's $1.6B Break Fee Deduction
The U.S. Department of Justice agreed to stop fighting a key U.S. Tax Court ruling that allowed pharmaceutical giant AbbVie to claim a $1.6 billion termination fee to an Irish biotechnology company as an ordinary tax deduction, according to a filing in the Seventh Circuit.
-
February 08, 2026
HMRC Nets £246M In Evasion-Focused Inheritance Tax Probes
Britain's tax authority has recovered an additional £246 million ($336 million) in inheritance tax secured by investigations, according to data released Sunday.
-
February 06, 2026
4 Takeaways From The EU's Latest Trade Agreements
The European Union recently cemented formal trade agreements with India and Mercosur, a group of Latin American countries, which — along with creating certainty for businesses in the regions — strike a sharp contrast with the approach taken in framework deals reached by President Donald Trump. Here, Law360 examines four takeaways from the two trade agreements announced by the EU.
-
February 06, 2026
Trump Orders 25% Tariff For Countries With Biz Ties To Iran
President Donald Trump signed an executive order Friday afternoon that threatens a 25% tariff on the imports entering the U.S. of countries found to be purchasing goods or services from Iran.
-
February 06, 2026
Partnership Asks Justices To Restore $23M Loss Deduction
A partnership asked the U.S. Supreme Court to revive its $23 million loss deduction involving a Brazilian company, saying in a petition docketed Friday that the Second Circuit wrongly blocked a key argument and that an IRS anti-abuse regulation applied against the partnership should be invalidated.
Expert Analysis
-
Supreme Court Term Limits Would Carry Hidden Risk
While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
-
Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave
The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.
-
AI Evidence Rule Tweaks Encourage Judicial Guardrails
Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.
-
The Law Firm Merger Diaries: Getting The Message Across
Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.
-
Horizontal Stare Decisis Should Not Be Casually Discarded
Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.
-
10 Commandments For Agentic AI Tools In The Legal Industry
Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.
-
The Law Firm Merger Diaries: How To Build On Cultural Fit
Law firm mergers should start with people, then move to strategy: A two-level screening that puts finding a cultural fit at the pinnacle of the process can unearth shared values that are instrumental to deciding to move forward with a combination, says Matthew Madsen at Harrison.
-
Rare Tariff Authority May Boost US Battery Manufacturing
Finalizing preliminary tariffs on active anode material from China — the result of a rare exercise of statutory authority finding that foreign dumping hampered the development of a nascent U.S. industry — should help domestic battery manufacturing, but potential price increases could discourage related clean-energy use, say attorneys at MoloLamken.
-
Considerations When Invoking The Common-Interest Privilege
To successfully leverage the common-interest doctrine in a multiparty transaction or complex litigation, practitioners should be able to demonstrate that the parties intended for it to apply, that an underlying privilege like attorney-client has attached, and guard against disclosures that could waive privilege and defeat its purpose, say attorneys at DLA Piper.
-
The Law Firm Merger Diaries: Making The Case To Combine
When making the decision to merge, law firm leaders must factor in strategic alignment, cultural compatibility and leadership commitment in order to build a compelling case for combining firms to achieve shared goals and long-term success, says Kevin McLaughlin at UB Greensfelder.
-
What To Watch As NY LLC Transparency Act Is Stuck In Limbo
Just about a month before it's set to take effect, the status of the New York LLC Transparency Act remains murky because of a pending amendment and the lack of recent regulatory attention in New York, but business owners should at least prepare for the possibility of having to comply, says Jonathan Wilson at Buchalter.
-
Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar
Deputy Attorney General Todd Blanche’s recent suggestion that the D.C. Bar would be prevented from reviewing misconduct complaints about U.S. Department of Justice attorneys runs contrary to federal statutes, local rules and decades of case law, and sends the troubling message that federal prosecutors are subject to different rules, say attorneys at HWG.
-
8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright
The Eighth Circuit’s recent decision invalidating transfer pricing regulations in 3M Co. v. Commissioner may be the most significant tax case implementing Loper Bright's rejection of agency deference as a judicial tool in statutory construction, says Edward Froelich at McDermott.