International

  • August 22, 2025

    Liberty Global $240M Foreign Tax Credit Bid Fails At 10th Circ.

    Liberty Global cannot claim $240 million in foreign tax credits for the sale of a Japanese affiliate, the Tenth Circuit ruled Friday, rejecting the telecommunications giant's contention that a statutory provision allows it to recharacterize the proceeds as overseas income.

  • August 22, 2025

    Canada To Toss Tariffs On US Goods Under USMCA

    The Canadian government will remove retaliatory tariffs on U.S. goods that comply with the United States-Mexico-Canada Agreement, excluding steel, aluminum and automobiles, in a move aimed at jump-starting trade talks akin to an exemption made by the U.S. government, Canada's prime minister said Friday.

  • August 22, 2025

    HMRC Tightens Pension Tax Relief Claims By Higher Earners

    The U.K. is restricting pension tax relief claims for higher earners in a change coming into effect next month, Britain's tax authority said.

  • August 22, 2025

    Slovakian Gov't Proposes 3% To 5% Digital Services Tax

    Slovakia is proposing a digital services tax on companies including Meta, Google and Netflix, with a senior government official saying the ability of large tech companies to avoid Slovakian income taxes gives them an unfair advantage over local businesses.

  • August 22, 2025

    Taxation With Representation: Kirkland, Weil, Fried Frank

    In this week's Taxation With Representation, private equity firm Thoma Bravo buys human resources software provider Dayforce Inc. in a take-private deal, Lowe's buys Foundation Building Materials, Nexstar Media Group Inc. acquires fellow media company Tegna Inc., and Soho House & Co. Inc. inks a take-private deal with hotel operator MCR.

  • August 22, 2025

    IRS Guidance Sparks Mixed Reaction For Solar, Wind Projects

    The IRS recently narrowed the way large solar and wind energy development projects can set their construction start dates to qualify for certain tax credits, a change offering relief for some developers but new hurdles for others depending on the stage, type and size of the project.

  • August 22, 2025

    OECD Recognizes Brazil's Implementation Of Global Min. Tax

    The Organization for Economic Cooperation and Development has recognized Brazil's 15% corporate minimum tax as meeting the requirements for the international minimum tax framework known as Pillar Two, the country's Ministry of Finance announced.

  • August 21, 2025

    Omni Bridgeway Looks To Enforce $13M Albania Award

    Litigation funder Omni Bridgeway is urging a D.C. federal court to let it seize assets belonging to Albania as it looks to enforce an arbitral award now worth some $13 million that the country has ignored for years, in a nearly decade-old dispute stemming from taxes on oilfield projects.

  • August 21, 2025

    Man Who Hid Account From Wife Owes FBAR Fines, US Says

    A claim by the owner of a check-cashing business that he only meant to hide a foreign bank account from his wife during divorce proceedings doesn't excuse his failure to report the money to the Internal Revenue Service, the U.S. told a California federal court.

  • August 21, 2025

    EU, US Agree To Eliminate Industrial Tariffs

    The European Union and the U.S. have agreed on new terms to the trade agreement to eliminate EU tariffs on U.S. industrial products and implement a 15% U.S. tariff cap for most other sectors, according to a joint statement issued Thursday.

  • August 21, 2025

    Treasury Gets New Acting International Tax Counsel

    A deputy international tax counsel for the U.S. Department of the Treasury has been elevated to serve as acting counsel, he said in a post on LinkedIn.

  • August 21, 2025

    G7 Deal May Undermine Global Minimum Tax Enforcement

    The U.S. government's agreement with the Group of Seven nations to effectively exempt American companies from the 15% global minimum tax may hollow out enforcement of the international regime, in part because other multinational corporations may pursue similar treatment.

  • August 21, 2025

    Prosecutors Can Hunt Lawyer's Assets In Castle Fraud Case

    A London court ruled Thursday that prosecutors could go ahead with efforts to claw back money from a former lawyer who was imprisoned for more than a decade for defrauding an American property developer out of £10.5 million ($14 million.) 

  • August 21, 2025

    Health Insurance Uptick Fuels £123M Rise In UK Tax Revenue

    Mounting pressure on Britain's public healthcare system is spurring the uptake of health insurance products and boosting government tax revenue, financial services consultancy Broadstone said Thursday.

  • August 20, 2025

    Australia Offers Compliance Guidelines For New Debt Rules

    The Australian Taxation Office published guidance Wednesday aimed at helping companies flag potential compliance risks as they reorganize in response to recent tax law changes that limit the amount of debt a corporation can use to fund its operations.

  • August 20, 2025

    IRS To Nix Recent Rules On Disregarded Foreign Payments

    The U.S. Treasury Department and IRS said Wednesday that they're planning to remove rules issued in January that would have forced companies to recognize income from payments that are disregarded for U.S. taxes yet reduce income in a foreign jurisdiction, a move prompted by criticism from businesses.

  • August 20, 2025

    Nutter Welcomes Tax Atty In NY From Fox Horan

    Less than a month after announcing it had grown its ranks by 8% with the addition of 13 attorneys in three states, Nutter McClennen & Fish LLP said earlier this week that it has hired a New York-based tax attorney from Fox Horan & Camerini LLP.

  • August 20, 2025

    IRS Lost Lien In Bankruptcy, Man Says In $28M Tax Battle

    The Internal Revenue Service jettisoned any federal tax lien it claims to have against a man by filing an unsecured claim in his bankruptcy case, he told a Florida federal court Wednesday in response to the government's $28 million lawsuit against him.

  • August 20, 2025

    Ex-Chelsea Soccer Player Ordered To Pay £466K To HMRC

    A former soccer player turned ESPN pundit must pay back nearly £466,000 ($628,300) in taxes on film company investments to HM Revenue & Customs, a London tribunal ruled.

  • August 20, 2025

    Prosecutors Want £10.5M From Lawyer In Castle Fraud Case

    A lawyer imprisoned for more than a decade for misappropriating money sent by an American property developer to buy a castle in Scotland owes his victims £10.5 million ($14 million), prosecutors told a London judge on Wednesday.

  • August 19, 2025

    IRS To Float Rules Aimed At Easing Corporate Moves To US

    The IRS announced plans Tuesday to propose regulations that would make it easier for publicly traded foreign corporations that own U.S. real estate to move their official base to the U.S. without facing unexpected tax issues.

  • August 19, 2025

    Fed. Circ. Won't Revisit Steel Duties On German Companies

    The Federal Circuit denied Tuesday a request for it to reconsider a precedential opinion upholding steel duties on German companies imposed after the U.S. Department of Commerce applied adverse facts available in an antidumping investigation.

  • August 19, 2025

    Medtronic Sees Tariffs Adding $185M To Costs This Year

    Medtronic expects tariffs to add $185 million to its costs over the course of its current fiscal year, an amount lower than a previous estimate due to the company's efforts to lessen tariffs' impact, an executive said Tuesday in an earnings call.

  • August 19, 2025

    NJ Man Gets 30 Months For Russian Arms Dealing Scheme

    A dual U.S.-Russian national was sentenced in a New York federal court to 30 months in prison after pleading guilty to his role in a scheme to smuggle sensitive, U.S.-made technology to further Russia's weapons development, prosecutors announced.

  • August 19, 2025

    Trump Tariff Suit Belongs In Trade Court, Gov't Tells DC Circ.

    Suits challenging President Donald Trump's imposition of emergency tariffs belong in the U.S. Court of International Trade and a D.C. federal judge improperly considered a case lodged by Illinois-based toy makers in his court, the government told the D.C. Circuit.

Expert Analysis

  • Crisis Management Lessons From The Parenting Playbook

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    The parenting skills we use to help our kids through challenges — like rehearsing for stressful situations, modeling confidence and taking time to reset our emotions — can also teach us the fundamentals of leading clients through a corporate crisis, say Deborah Solmor at the Wisconsin Alumni Research Foundation and Cara Peterman at Alston & Bird.

  • Adapting To Private Practice: From NY Fed To BigLaw

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    While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.

  • Top 3 Litigation Finance Deal-Killers, And How To Avoid Them

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    Like all transactions, litigation finance deals can sometimes collapse, but understanding the most common reasons for failure, including a lack of trust or a misunderstanding of deal terms, can help both parties avoid problems, say Rebecca Berrebi at Avenue 33 and Boris Ziser at Schulte Roth.

  • A 2-Step System For Choosing A Digital Asset Reporting Path

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    Under the Internal Revenue Service's new digital asset reporting regulation, each type of asset may have three potential reporting destinations, so a detailed testing framework can help to determine the appropriate path, says Keval Sonecha at Sonecha & Amlani.

  • How Attys Can Use A Therapy Model To Help Triggered Clients

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    Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.

  • 3 Steps For In-House Counsel To Assess Litigation Claims

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    Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.

  • IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement

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    Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.

  • Adapting To Private Practice: From DOJ Enviro To Mid-Law

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    Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.

  • Legal Ethics Considerations For Law Firm Pro Bono Deals

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    If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.

  • 10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks

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    The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.

  • Power To The Paralegals: The Value Of Unified State Licensing

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    Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.

  • 10 Soft Skills Every GC Should Master

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    As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.

  • An Unrestrained, Bright-Eyed View Of Legal AI's Future

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    Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.

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