International

  • July 15, 2026

    Eaton Says IRS Position Turns 'Arm's Length' On Its Head

    The IRS' argument in support of its income allocations to Eaton Corp. from an Irish affiliate effectively inverts the arm's-length standard underlying U.S. transfer pricing law, seeking to price transactions between related companies by assuming non-arm's-length behavior, the company told the U.S. Tax Court.

  • July 15, 2026

    CIT Judge Says Order Incoming For Next Tariff Refund Phase

    The U.S. Court of International Trade judge overseeing U.S. Customs and Border Protection's development of a duty refund system for tariffs struck down by the U.S. Supreme Court forecast new directions for the government as it prepares another phase of its tariff refund system, according to an order published Wednesday.

  • July 15, 2026

    Siemens Wins Tax Deduction In IRS Rules Mismatch Case

    Siemens Medical Solutions is allowed the full dividends-received deduction it claimed for 2019, the U.S. Tax Court held Wednesday, throwing out an IRS regulation that attempted to reduce the deduction by aligning the effective date of different provisions under 2017 tax legislation.

  • July 15, 2026

    HMRC Still Weighing How To Treat Offshore Interest Income

    There's a general consensus that the United Kingdom's tax system creates difficulties for taxpayers with offshore interest income, but there are differing views on how to tackle the issue, so no fixes are being proposed for now, HM Revenue & Customs said Wednesday in summarizing a consultation.

  • July 15, 2026

    Energy Tax Applies To Propane Used For Tests, EU Court Says

    The European Union's energy tax directive applies to propane used by a German company to test gas turbine burners, even though it wasn't burning the propane to generate heat per se except to test the burners, the European General Court said Wednesday.

  • July 15, 2026

    Port Co. Defends Tax Claim On £57M Project At Upper Tribunal

    Liverpool's port operator defended its claim at the Upper Tribunal on Wednesday to tax allowances on more than £57 million ($76.3 million) in construction costs after Britain's tax authority argued that the project didn't qualify for the tax breaks.

  • July 15, 2026

    Russia Sanctions Bill Goes Too Far On Tariff Power, Dems Say

    A reworked version of a bipartisan bill aimed at sanctioning Russia over the war in Ukraine wrongly places too much tariff power in the hands of President Donald Trump, some leading congressional Democrats said.

  • July 15, 2026

    Pillar 2 Revenue Intake Falls Short Of Predictions, OECD Says

    The worldwide corporate 15% minimum tax agreement known as Pillar Two has so far brought in less revenue than expected, the Organization for Economic Cooperation and Development said Wednesday.

  • July 15, 2026

    EU Court Says Danish VAT Rule Must Truly Target Tax Evasion

    Denmark can set a 100% minimum ownership threshold for businesses wishing to form a VAT group only if national courts deem the requirement necessary and proportionate for combating tax abuse, a European Union court said Wednesday.

  • July 14, 2026

    Bike Seller Says IRS' Undervaluation Caused $3M Deficiency

    A California bicycle seller told the U.S. Tax Court that the IRS' faulty appraisal of its value caused the agency to mischaracterize a transaction with its parent company as a discharge of indebtedness and a $15.5 million income increase, leading to a $3.3 million deficiency assessment.

  • July 14, 2026

    IRS Ethics Guidance Highlights AI Billing Tensions

    Recent IRS ethics guidance urged attorneys to acknowledge the time-saving features of artificial intelligence when billing clients, underlining the legal industry's ongoing reckoning with how, or if, this technology fits into the traditional practice of charging by the hour.

  • July 14, 2026

    Port Co. Can't Claim Tax Breaks On £57M, Tribunal Told

    A London tribunal was wrong to rule that Liverpool's port operator can claim tax allowances on £57.1 million ($76.4 million) spent constructing part of a deep-water container terminal, the U.K. tax authority argued Tuesday.

  • July 14, 2026

    US Refunded $49.2B In Tariffs Last Month, Treasury Says

    The U.S. government issued tariff refunds totaling more than $49.2 billion in June, dragging down customs duties to account for a monthly net loss of $25.5 billion in the federal accounts, according to the U.S. Department of the Treasury.

  • July 14, 2026

    3 Convicted In €50M German VAT Fraud With Cars, Masks

    A Berlin court convicted three individuals, including a tax adviser, tied to a €50 million ($57.1 million) value-added tax fraud involving luxury vehicles and medical face masks, the European Public Prosecutor's Office said Tuesday.

  • July 14, 2026

    Greece Seizes Evidence In Suspected €46.9M VAT Fraud

    Greek authorities seized evidence and assets from companies tied to a suspected value-added tax fraud scheme involving small electronic goods that produced €46.9 million ($53.6 million) in lost tax revenue, the European Public Prosecutor's Office said Tuesday.

  • July 14, 2026

    EU Tax Lead Urges Reconsideration Of Interest Limit Rule

    Policymakers should reflect on the rationale behind the European Union's interest limitation rule — a tool that can increase firms' tax bases — as it is hitting companies that aren't circumventing tax mandates, a senior EU official said Tuesday.

  • July 13, 2026

    Israeli Law Firm Counters Gov't Bid To Toss GILTI Reg Suit

    An Israeli law firm asked the D.C. federal court Monday to disregard the government's attempt to end its suit aiming to scrap regulations that implemented the 2017 tax law's global intangible low-taxed income regime, arguing that its case is strong enough for a quick win.

  • July 13, 2026

    McKesson Says IRS Overreads Law Backing Pricing Rules

    Pharmaceutical giant McKesson asked a Texas federal court to invalidate transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. government mistakenly thinks the underlying statute gives the IRS "near-limitless authority" to define key terms.

  • July 13, 2026

    Biofuel Tax Fraudster Loses Bid For Extra Sentence Reduction

    A Utah federal judge declined to reduce further the original sentence of an accomplice in a $500 million biofuel production tax credit fraud scheme, finding that his prior reduction to 12 years had sufficiently reflected his cooperation in the trial of another defendant.

  • July 13, 2026

    US Biz Group Urges EU To Honor Side-By-Side Treatment

    A lobbying group representing U.S. companies called on the European Union to respect the country's side-by-side agreement as the bloc continues to work on a tax simplification overhaul.

  • July 13, 2026

    UK Gov't To Implement Side-By-Side Tax Rules

    Britain's tax authority set out new rules for the U.K.'s top-up tax regime, including the side-by-side safe harbor rule for U.S. multinational companies, according to a policy paper published Monday.

  • July 13, 2026

    Bin Maker Too Late To Appeal £161K Tax Bill, Tribunal Says

    A trash bin maker is time-barred from appealing more than £161,000 ($215,000) in customs duties and import value-added tax levied on its products, the First-tier Tribunal said in a decision.

  • July 13, 2026

    UK To Exempt Stablecoins From Capital Gains Tax

    Britain's tax authority will allow a capital gains tax exemption for disposals of stablecoins pegged to a fiat currency or other tangible assets, according to a policy paper published Monday.

  • July 13, 2026

    HMRC Sets Out Oil & Gas Levy To Replace Windfall Tax

    Britain's tax authority laid out the new tax regime for North Sea oil and gas to replace the windfall levy on energy giants in a policy paper published Monday.

  • July 10, 2026

    US-Canada Stalemate Expected To Hold Amid USMCA Review

    The trade stalemate between the U.S. and Canada is likely to continue through a drawn-out review process for the U.S.-Mexico-Canada Agreement, though companies will benefit from an underlying level of stability as the deal remains in effect, trade lawyers said.

Expert Analysis

  • 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.

  • 5 Real Estate Takeaways From Trump's Sweeping Tax Law

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    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

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    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

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    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

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    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

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    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

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    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

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    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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