International
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January 12, 2026
European Union Carrying Out Revised Min. Corp. Tax Regime
The European Union's executive body is implementing changes to the 15% minimum corporate tax regime across the trade bloc after a renegotiation of Pillar Two last week, according to a notice published Monday.
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January 12, 2026
Solar Co. Blames Broker's Error For $6M Tariff Bill
A renewable energy company wants its customs broker and agent held responsible for over $6 million in antidumping and countervailing duties it had to pay on imported solar panels due to the broker's alleged failure to properly record them.
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January 12, 2026
India High Court Rules Post-Merger Shares Can Be Taxed
The Supreme Court of India ruled that if companies combine to create a new business with shares that are worth more than those of the individual corporations, investors may owe taxes on the difference in value.
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January 12, 2026
OECD Issues Guidance On Real-Time Reporting For VAT
The OECD has released guidance for policymakers on designing mandates for real-time reporting of transactions to tax authorities for value-added tax purposes, which are increasingly being considered and adopted by countries worldwide.
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January 09, 2026
US Disputes Right To Trial Before IRS Assesses FBAR Fines
A California man wasn't entitled to a jury trial prior to the IRS assessing penalties for his failure to report foreign bank accounts because the U.S. Supreme Court decision he cited limiting administrative courts for securities fraud doesn't apply, the government told a California federal court.
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January 09, 2026
EU Council Approves Trade Pact With 4 S. American Countries
A legislative arm of the European Union approved the bloc's free trade agreement with four South American countries Friday, taking steps to create the largest global free trade zone.
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January 09, 2026
Taxation With Representation: King & Spalding, Torys, Milbank
In this week's Taxation With Representation, power generation company Vistra Corp. acquires Cogentrix Energy from Quantum Capital Group, real estate firm Minto Group partners with Crestpoint Real Estate Investments to take Minto's apartment-focused real estate investment trust private, and engineering services provider Jacobs acquires a remaining stake in PA Consulting.
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January 09, 2026
China To Cut VAT Export Tax Rebates For Solar Panels
China will eliminate its value-added tax export rebates for photovoltaic and other related products starting April 1, the country's Ministry of Finance said Friday.
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January 09, 2026
UK Gov't Rules Out Farm Inheritance Tax Concessions
The U.K.'s Labour government will not make more concessions to farmers on its inheritance tax rule changes for agricultural land after a recent compromise on the tax threshold, a minister said in a speech at a conference.
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January 08, 2026
OECD, Gov't Officials Praise 'Side-By-Side' Tax Deal
Officials from Germany, the U.S. and the OECD on Thursday hailed a recently finalized agreement among roughly 150 countries as a balanced solution to the U.S.' desire for a global minimum tax regime that operates "side by side" with its own rules.
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January 08, 2026
Courts Back Agencies Despite Loper Bright Ruling, DOJ Says
Appellate courts have mostly upheld federal agencies' interpretation of ambiguous statutes, including tax disputes, even after the U.S. Supreme Court's 2024 landmark decision that limited agency deference, a U.S. Department of Justice attorney said Thursday.
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January 08, 2026
US Asks 6th Circ. To Revive Reg In $89M FedEx Tax Suit
The Sixth Circuit should vacate a judgment that allowed FedEx an $89 million refund by discarding a regulation preventing companies from claiming foreign tax credits on earnings offset by losses, which aren't taxed in the U.S., the government said in an opening brief.
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January 08, 2026
Irish R&D Tax Credit Linked To €7B In Spending, Gov't Says
Ireland's tax credit for research and development is linked to €7 billion ($8.2 billion) in related spending by companies on the island in 2023 while costing the government about €1.4 billion, the Irish Department of Finance said Thursday.
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January 08, 2026
Data Supervisor Warns Against Exceptional VAT Info Searches
The European Union's plans to crack down on value-added tax fraud may blur the line between data cooperation and law enforcement, potentially undermining data protection, the EU's data supervisor warned Thursday.
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January 08, 2026
Audits Get Final Word On Economic Substance, IRS Atty Says
IRS attorneys provide legal guidance during audits on whether a transaction lacks economic substance, but examiners make the ultimate determination, an agency associate chief counsel said Thursday while explaining how the agency applies a powerful anti-abuse tool in audits.
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January 08, 2026
HSBC To Pay €300M To Settle French Tax Fraud Probe
HSBC has agreed to pay French authorities more than €300 million ($350 million) in fines and unpaid taxes to settle a criminal probe into how the bank's Paris branch handled dividend arbitrage transactions between 2014 and 2019, public prosecutors revealed Thursday.
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January 08, 2026
OECD Project Seeks To Ease Access To Tax Dispute Process
A new project at the OECD will aim to ensure that double-tax cases are eligible to be resolved through bilateral government negotiations under treaties no matter how they're characterized by a country's tax authority, a U.S. Treasury Department official said Thursday.
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January 07, 2026
US Official Gives Rationale For OECD Global Mobility Changes
Recent changes to the commentary on when a home office gives rise to a permanent establishment in the OECD model tax treaty reflect delegates' unhappiness with previous language on the availability of an office, a U.S. Treasury Department official said Wednesday.
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January 07, 2026
Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says
The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed Swiss account, the Second Circuit said Wednesday, upholding a lower court's judgment.
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January 07, 2026
Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies
The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025.
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January 07, 2026
Gov't Slow-Rolling Lower Fee For Expatriation, Court Told
The U.S. State Department has impermissibly slow-walked the rollout of a reduced fee for renouncing U.S. citizenship, a Paris-based group that represents Americans permanently residing abroad told a D.C. federal court.
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January 07, 2026
Australia Increasingly Blocking Tax Debtors From Leaving
The Australian Taxation Office is increasingly barring international travel for people with tax debts who it suspects of trying to flee their obligations, it said Wednesday.
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January 07, 2026
IRS Mulling Budget Bill's Changes To CFC Rules, Official Says
The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.
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January 07, 2026
Irish Tax Revenue Up €8.6B In 2025, Corp. Taxes Up 17%
The Irish government saw tax revenue rise by €8.6 billion ($10 billion) in 2025, with corporate tax receipts up by 17.2%, the Department of Finance said in its annual report.
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January 07, 2026
Portuguese Tax System Too Complex, OECD Says
The Portuguese government needs to simplify the country's tax regime to boost economic growth and raise living standards, the Organization for Economic Cooperation and Development said Wednesday.
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.