International

  • March 13, 2026

    IRS Seeks To Dismiss Meta's Claim On Interest, Penalty

    The IRS did not erroneously assess interest and penalties against Meta Platforms during 2020, when the company said it was protected under a diaster-relief provision, the agency argued as it urged the U.S. Tax Court to throw out the social media giant's challenge of such an assessment.

  • March 13, 2026

    HMRC Set To Fully Absorb Valuation Office By April

    The U.K.'s Valuation Office Agency will become fully integrated into HM Revenue & Customs next month, the office said, bringing property valuations into the remit of fiscal administration for the first time in decades ahead of the imposition of a new tax on high-value properties.

  • March 13, 2026

    Greenberg Traurig Adds Taft Private Wealth Partner In Chicago

    Greenberg Traurig LLP has hired a former Taft Stettinius & Hollister LLP partner, who joins the Chicago team to continue her practice focused on private wealth services, including advising individuals, families and businesses on estate planning and tax matters.

  • March 13, 2026

    Taxation With Representation: Paul Hastings, Duane Morris

    In this week's Taxation With Representation, uniform maker Cintas Corp. acquires workwear company UniFirst Corp., Controlled Thermal Resources Holdings Inc. plans to go public by merging with a special purpose acquisition company, and a Shell USA Inc. subsidiary sells Jiffy Lube International Inc. to Monomoy Capital Partners.

  • March 13, 2026

    OECD Business Group Calls For Further Pillar 2 Planning

    The OECD's business stakeholder group on Friday called for "continued refinement" of Pillar Two readiness plans to ensure a smooth application of the 15% global minimum tax on corporate profits. 

  • March 12, 2026

    Tariff Refund System Taking Shape, US Customs Tells CIT

    U.S. Customs and Border Protection is making progress developing a system for importers to claim refunds for the global tariff regime struck down by the U.S. Supreme Court, an official told the U.S. Court of International Trade on Thursday.

  • March 12, 2026

    Microsoft, Michigan Settle Cost-Share Receipts Tax Fight

    Microsoft and Michigan reached a settlement over the company's challenge to the state's tax treatment of its cost-sharing agreement receipts with foreign affiliates, according to a dismissal order entered Thursday by the state's Tax Tribunal.

  • March 12, 2026

    IRS Allows 15% Of KFC Parent's Domestic Production Claim

    The IRS and the parent of Pizza Hut, KFC and Taco Bell agreed that the company's total deductions for domestic production activities during 2013-2015 were $1.6 million — roughly 15% of the $10.7 million the company had claimed as deductions for the three years.

  • March 12, 2026

    Reeves Says Energy Windfall Tax May Not Apply By Late 2027

    The U.K.'s energy profits levy is expected to no longer apply to oil and gas operations in the North Sea in the last quarter of 2027, especially if the current Middle East crisis de-escalates and energy prices stabilize, Chancellor of the Exchequer Rachel Reeves told an H&M Treasury committee.

  • March 12, 2026

    Alleged IRS Errors Don't Merit Injunction, Judge Advises

    A Puerto Rico magistrate judge recommended denying a taxpayer's bid to block the IRS from assessing her tax liabilities while the agency's clerical errors that she alleges remain unresolved, holding that she faces uncertainties that don't rise to the level of irreparable harm.

  • March 12, 2026

    EU Top Court Allows Spain's Entertainment VAT Break Limit

    Spain's restriction on VAT deductions linked to entertainment expenses doesn't constitute a violation of European Union law, the bloc's top court said Thursday, rejecting a human resources firm's claim that the country was illegally blocking refunds on business costs.

  • March 11, 2026

    Costco Owes Shoppers Refunds For Voided Tariffs, Suit Says

    Costco shoppers are owed back the higher costs they paid as a result of President Donald Trump's global tariffs that the nation's highest court has since declared unlawful, according to a putative consumer class action filed Wednesday in Illinois federal court.

  • March 11, 2026

    Varian Case Backs $315M Siemens Deduction, Tax Court Told

    The U.S. Tax Court should restore $315 million of Siemens' foreign-dividend tax deduction for the same reasons it upheld a similar deduction for Varian Medical Solutions in 2024, an attorney for Siemens told the court Wednesday.

  • March 11, 2026

    Cos. Ask Court To Toss Trump's Revamped Global Tariffs

    Two companies are challenging President Donald Trump's revamped global tariff regime, telling the U.S. Court of International Trade that the circumstances required to justify the regime cannot exist.

  • March 11, 2026

    Dairy Giant Loses Bid For UK Tax Deductions On IP Transfers

    A London court on Wednesday dismissed a European dairy giant's appeal seeking corporate tax deductions for intellectual property transferred to the partnership by its corporate members.

  • March 11, 2026

    EU Refers Spain To Top Court For Inaction On VAT Directives

    Spain will be referred to the European Union's top court for failing to incorporate two legal directives on value-added tax into Spanish law by a December 2024 deadline, the EU's executive arm said Wednesday.

  • March 11, 2026

    Transfer Pricing Cases Collected £3.4B Last Year, HMRC Says

    The U.K. brought in £3.4 billion ($4.6 billion) in additional revenue from transfer pricing cases from 2024-2025, nearly double the amount from the previous year, according to HM Revenue & Customs data released Wednesday.

  • March 11, 2026

    Barrister's Libel Claim Against Neidle Dismissed As SLAPP

    A judge has struck out a barrister's £8 million ($11 million) libel claim against Dan Neidle, ruling on Wednesday that the case had no chance of succeeding and amounted to a strategic legal claim designed to silence the legal blogger. 

  • March 10, 2026

    Hewlett Packard To Fight IRS Transfer Pricing Adjustments

    Hewlett Packard Enterprise Co. disagrees with transfer pricing adjustments by the IRS and will challenge the agency's efforts to increase its taxable income, the company said in a quarterly report released Tuesday.

  • March 10, 2026

    Exxon Wins $27M Deduction In Canadian Tax Dispute

    The Tax Court of Canada backed Exxon Mobil's bid for a CA$36.2 million ($26.7 million) income deduction for expenses tied to an abandoned Alaskan pipeline project, holding that the company incurred the costs while conducting legitimate business operations.

  • March 10, 2026

    PE Group Asks 3rd Circ. To Overturn Fund's $100M Tax Bill

    The U.S. economy could face damaging consequences if the Third Circuit upholds a U.S. Tax Court decision finding a Cayman Islands hedge fund liable for a $100 million tax bill as a securities dealer, a private equity lobbying group told the court.

  • March 10, 2026

    French Tax Take Outpaces Economic Growth

    France's net tax revenue reached €610 billion ($710 billion) in fiscal year 2025, growing three times faster than GDP, the French tax authority said Tuesday.

  • March 10, 2026

    Portugal Warns Of Carbon Tax Abuse If Exemptions Granted

    A more lenient application of the European Union's carbon leakage tax in the bloc's outermost regions would risk tax evasion, Portugal's finance minister said during a meeting to discuss the bloc's economic agenda.

  • March 10, 2026

    Medtronic, IRS Pursuing Settlement In Transfer Pricing Case

    Medtronic and the Internal Revenue Service are exploring the possibility of settling their U.S. Tax Court case, the parties said, which would avoid the need for a third trial on the pricing intangibles that the Minnesota-based company licensed to its Puerto Rican affiliate in 2005 and 2006.

  • March 10, 2026

    Alston & Bird Adds Deals Pro From Proskauer To Tax Team

    Alston & Bird LLP announced on Tuesday that it has welcomed a tax attorney from Proskauer Rose LLP, saying that his hire will benefit its transactional team and its private equity clients.

Expert Analysis

  • The Law Firm Merger Diaries: Getting The Message Across

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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.

  • Rule Amendments Pave Path For A Privilege Claim 'Offensive'

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    Litigators should consider leveraging forthcoming amendments to the Federal Rules of Civil Procedure, which will require early negotiations of privilege-related discovery claims, by taking an offensive posture toward privilege logs at the outset of discovery, says David Ben-Meir at Ben-Meir Law.

  • Litigation Funding Could Create Ethics Issues For Attorneys

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    A litigation investor’s recent complaint claiming a New York mass torts lawyer effectively ran a Ponzi scheme illustrates how litigation funding arrangements can subject attorneys to legal ethics dilemmas and potential liability, so engagement letters must have very clear terms, says Matthew Feinberg at Goldberg Segalla.

  • E-Discovery Quarterly: Recent Rulings On Dynamic Databases

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    Several recent federal court decisions illustrate how parties continue to grapple with the discovery of data in dynamic databases, so counsel involved in these disputes must consider how structured data should be produced consistent with the requirements of the Federal Rules of Civil Procedure, say attorneys at Sidley.

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