International

  • December 12, 2025

    IRS To Revamp Voluntary Disclosure Program

    The Internal Revenue Service will be updating a program early next year that would allow taxpayers to voluntarily report previously undisclosed income as a way to resolve their tax issues to facilitate a simpler reporting process, the agency's criminal enforcement chief said Friday.

  • December 12, 2025

    Treasury Issues Final Rules For Taxing Foreign Gov't Income

    The U.S. Treasury Department issued final regulations Friday for determining whether income of foreign governments derived within the U.S. is taxable along with proposed regulations concerning when a foreign government has effective control of a commercial entity.

  • December 12, 2025

    Taxation With Representation: Cravath, Skadden, Debevoise

    In this week's Taxation With Representation, Paramount Skydance Corp. launches a hostile bid for Warner Bros. Discovery, challenging Netflix's deal to acquire the studio and streaming business, IBM acquires data streaming company Confluent, and natural gas company Antero Resources Corp. expands via a deal with HG Energy.

  • December 11, 2025

    Judge Slams Eaton Expert For Offering Legal Analysis

    A report submitted by one of Eaton's expert witnesses in its acquisition financing trial overstepped the limits of an expert's role, offering legal rather than economic analysis and seeming to advocate for the company​​​​, a U.S. Tax Court judge said Thursday.

  • December 11, 2025

    Fed Terminates 3 Actions Against Credit Suisse, JPMorgan

    The Federal Reserve said Thursday that it has terminated a trio of enforcement actions against Credit Suisse Group AG and JPMorgan Chase & Co., lifting consent orders that were tied to alleged illicit finance practices and trade surveillance failures.

  • December 11, 2025

    Wealth Taxes Can Succeed Despite Flaws, EU Panel Hears

    Wealth taxes have underperformed across the European Union because of design flaws, but this doesn't mean such levies can't work or that there are no alternatives, tax experts said Thursday.

  • December 11, 2025

    EU Corporate Tax Compliance Shortfall About €38B, Bloc Says

    Countries in the European Union didn't collect about €38 billion ($44.7 billion) in corporate income tax liabilities due to noncompliance in 2017 and about €128 billion of value-added tax liabilities in 2023, the bloc's executive branch said Thursday in a series of reports.

  • December 10, 2025

    Judge Probes IRS Expert On Method For Eaton's Credit Rating

    A U.S. Tax Court judge asked an IRS expert Wednesday about his calculation of a standalone credit rating for Eaton's U.S. group in 2012, when it acquired an Irish entity and inverted, noting that the expert, unlike ratings agency Standard & Poor's, factored in Eaton's debt to the Irish parent.

  • December 10, 2025

    Estonia Blocks OECD Adopting US' Global Min. Tax Exemption

    Estonia formally opposed the U.S. government's proposed exemption for American companies from the 15% global minimum tax's international provisions during an adoption procedure held by the OECD, the country's Ministry of Finance said Wednesday, blocking the adoption for now.

  • December 10, 2025

    Australia Issues Guidance On Tax Transparency Exemptions

    Australia will consider granting exemptions to public country-by-country reporting of tax information to companies that can demonstrate their compliance would reveal commercially sensitive information, violate Australian or foreign laws or negatively impact national security, according to final guidance issued by the Australian Taxation Office.

  • December 10, 2025

    Reeves Denies Gov't Authorized UK Budget Leak

    British Chancellor of the Exchequer Rachel Reeves told a parliamentary committee Wednesday that she didn't authorize briefings of policy discussions to the media ahead of the autumn budget statement.

  • December 10, 2025

    Frankfurt Police Seize Assets In VAT Fraud Crackdown

    Authorities in Frankfurt, Germany, searched two properties, seizing cash and documents, in a suspected case of value-added tax fraud, according to a statement Wednesday.

  • December 09, 2025

    Judge Wants Cost-Benefit Analysis Of Eaton Guarantees

    A U.S. Tax Court judge asked one of Eaton's experts Tuesday how much the company could have saved by issuing debt from its new Irish parent in 2012 instead of having the parent guarantee bonds the U.S. company issued to third parties.

  • December 09, 2025

    Tariffs Add Complexity To State Tax Systems, Tax Pros Say

    Tariffs promoted by President Donald Trump's administration are increasing state sales and use tax complexity and risk, which may not easily be undone even if the U.S. Supreme Court strikes the tariffs down, tax professionals said Tuesday.

  • December 09, 2025

    OECD's Average Tax-To-GDP Hits Record 34.1%, Report Says

    The OECD's average ratio of tax to gross domestic product reached a record 34.1% last year, the organization said Tuesday, marking the first annual increase since 2021.

  • December 09, 2025

    Sabre Tax Dispute Belongs In UK Court, British Airways Says

    Flight booking giant Sabre's lawsuit over a U.K. digital tax bill should be dismissed or left for a British court to rule on, British Airways told a Texas federal court, arguing that the digital services tax is a matter for U.K. law.

  • December 08, 2025

    Conservative Justices Probe 'Husk' Of FTC Firing Protections

    The U.S. Supreme Court's conservative majority pushed back Monday against the 90-year-old precedent permitting the removal only for cause of Federal Trade Commission members, and perhaps those serving other independent agencies, calling those safeguards a "dried husk" and wondering where to draw the line for protected agencies.

  • December 08, 2025

    Meta Fights $16B Tax Bill Over Facebook's Cost-Sharing Deal

    Facebook parent Meta Inc. is challenging a nearly $16 billion tax bill stemming from an agreement with an Irish affiliate to share the costs of developing intangibles, telling the U.S. Tax Court that the IRS can't relitigate issues the court already addressed.

  • December 08, 2025

    11th Circ. Affirms Tax Court Wrong Venue For FBAR Challenge

    The U.S. Tax Court isn't the right venue for a couple to challenge the Internal Revenue Service's denial of a hearing over the agency withholding their Social Security benefits to cover penalties stemming from their failure to report foreign bank accounts, the Eleventh Circuit affirmed Monday.

  • December 08, 2025

    Hogan Lovells Adds Latham Corporate Ace In Houston

    Hogan Lovells announced Monday that it has bolstered its tax, pensions and benefits offerings with a Houston-based attorney who came aboard from Latham & Watkins LLP.

  • December 05, 2025

    Eaton's Position On Parental Support Conflicting, Judge Says

    Eaton is telling "different stories at different times" about the ability of its foreign parent company to step in and pay the U.S. company's debt obligations to third parties, Tax Court Judge Albert Lauber said in questioning one of the company's experts Friday.

  • December 05, 2025

    Swiss To Charge VAT To Platforms For Software, Streaming

    Switzerland is planning to collect value-added taxes from platforms for selling electronic services like software, streaming and digital content, rather than from individual sellers, extending a system already in place for mail-order e-commerce companies, the country's finance department said Friday.

  • December 05, 2025

    IRS-ICE Data Swap Halt Irrelevant In Other Suit, DC Circ. Told

    A D.C. federal court's order pausing the Internal Revenue Service's ability to share confidential taxpayer addresses with immigration enforcement officials should not impact a separate D.C. Circuit proceeding over whether the information-sharing agreement complies with taxpayer privacy protections, the U.S. government told the D.C. Circuit.

  • December 05, 2025

    Huntsman Disputes $28.6M Tax Bill From Cut Capital Loss

    Multinational chemical manufacturer Huntsman is challenging the IRS over a $28.6 million tax bill that resulted from the agency reducing its carried-forward loss from selling a spun-off pigments business, according to a petition filed in the U.S. Tax Court.

  • December 05, 2025

    Asian Tax Systems Seen As More Fair, OECD Report Says

    Taxpayers in Asian countries are more likely to perceive their tax systems as equitable compared to individuals in other regions, according to a report from the Organization for Economic Cooperation and Development and international accounting groups.

Expert Analysis

  • Law School's Missed Lessons: Educating Your Community

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    Nearly two decades prosecuting scammers and elder fraud taught me that proactively educating the public about the risks they face and the rights they possess is essential to building trust within our communities, empowering otherwise vulnerable citizens and preventing wrongdoers from gaining a foothold, says Roger Handberg at GrayRobinson.

  • 5 Crisis Lawyering Skills For An Age Of Uncertainty

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    As attorneys increasingly face unprecedented and pervasive situations — from prosecutions of law enforcement officials to executive orders targeting law firms — they must develop several essential competencies of effective crisis lawyering, says Ray Brescia at Albany Law School.

  • It's Time For The Judiciary To Fix Its Cybersecurity Problem

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    After recent reports that hackers have once again infiltrated federal courts’ electronic case management systems, the judiciary should strengthen its cybersecurity practices in line with executive branch standards, outlining clear roles and responsibilities for execution, says Ilona Cohen at HackerOne.

  • Rules Of Origin Revamp May Be Next Big Trade Development

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    The rules of origin for determining what tariff applies to any given import appear to be on the cusp of an important rethink, and it seems likely that the administration will try to align the rule with its overall tariff strategy in one of three ways, says Ted Posner at Baker Botts.

  • SDNY OpenAI Order Clarifies Preservation Standards For AI

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    The Southern District of New York’s recent order in the OpenAI copyright infringement litigation, denying discovery of The New York Times' artificial intelligence technology use, clarifies that traditional preservation benchmarks apply to AI content, relieving organizations from using a “keep everything” approach, says Philip Favro at Favro Law.

  • High Court, Not A Single Justice, Should Decide On Recusal

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    As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.

  • Adapting To Private Practice: 3 Tips On Finding The Right Job

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    After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.

  • Painting Makes Me A Better Lawyer

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    Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.

  • Protecting Sensitive Court Filings After Recent Cyber Breach

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    In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.

  • What Ethics Rules Say On Atty Discipline For Online Speech

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    Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.

  • 2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers

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    Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.

  • Junior Attys Must Beware Of 5 Common Legal Brief Mistakes

    Excerpt from Practical Guidance
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    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

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    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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