International

The Tax Angle: Green Energy Permits, Enhanced ACA Credits

Stephen K. Cooper
Editor-at-Large

From a look at permitting delays holding up solar and wind tax credit projects to uncertainty surrounding the renewal of Affordable Care Act enhanced premium tax credits, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

Foreign Entity Rules Begin To Shape Clean Energy Deals

Keith Goldberg

The recently enacted federal budget that attaches stricter foreign supply chain and business ownership rules to clean energy tax credits has started to take practical effect, with project developers rewriting agreements to avoid getting snagged in the new regulatory regime.

Pillar 2 At 4: High Compliance Costs, Low Tax Liabilities

Natalie Olivo
Senior Tax Correspondent

Four years after countries agreed to an international minimum corporate tax regime known as Pillar Two, finance executives and policy observers are voicing a common refrain: multinational companies likely will pay more compliance costs than actual taxes under the new rules.

Junior Attys Must Beware 5 Common Legal Brief Mistakes

Excerpt from Practical Guidance

Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.