International

  • July 30, 2025

    Dechert Adds Tax Pro From PwC In DC

    Dechert LLP has continued to grow its financial services platform in Washington, D.C., with the hire of a partner from PwC.

  • July 30, 2025

    Trump To Hit India With 25% Tariff, 'Penalty' Starting Friday

    President Donald Trump said Wednesday that he planned to impose a 25% tariff on India beginning Friday, plus an additional "penalty," citing the country's energy and defense dealings with Russia as top concerns along with trade barriers.

  • July 30, 2025

    Updates To Switzerland-France Tax Treaty Enter Into Force

    Changes to Switzerland and France's tax treaty have come into effect, including new rules for cross-border remote workers and measures to target aggressive tax planning, the Swiss government said.

  • July 30, 2025

    Roughly 34K Cos. Have Claimed UAE Late Registration Relief

    Nearly 34,000 corporations have taken advantage of the United Arab Emirates' penalty waiver for late tax registration applications, the county's tax authority announced.

  • July 30, 2025

    OECD Releases Spreadsheets For Min. Tax, Crypto Reporting

    The OECD released a blueprint Wednesday for tax authorities to identify errors in tax returns shared by other authorities pursuant to the 15% global minimum tax, along with an updated blueprint for authorities to swap information on cryptocurrency holdings.

  • July 30, 2025

    UK Gov't Forced To Repay £48.7M In Pension Overtaxation

    The government has had to hand back £48.7 million ($64.7 million) in the past three months to Britons who paid too much tax when tapping into their pension savings, figures revealed Wednesday, as experts say a fix for the long-running tax provision so far has shown little effect.

  • July 29, 2025

    IRS To Permit Corp. AMT Top-Down Election For Partnerships

    The IRS said Tuesday that revised proposed rules for the corporate alternative minimum tax will accommodate different approaches to calculating a partnership's investment income, including the top-down approach permitting a corporate partner to use figures that the partner reported in its own financial statement.

  • July 29, 2025

    Economists Decry Federal Budget's Looser Interest Deduction

    It's regrettable that Congress loosened rules allowing companies to deduct interest costs from tax liabilities in its latest budget, which as a whole is poised to worsen the country's fiscal trajectory while prompting higher interest rates, a panel of economists said Tuesday.

  • July 29, 2025

    Trump To Make Call On Further Delay Of Higher China Tariffs

    President Donald Trump will decide whether to extend a tariff delay another 90 days for Chinese imports after U.S. Treasury Secretary Scott Bessent and U.S. Trade Representative Jamieson Greer met with Chinese officials to discuss trade matters, the officials told reporters Tuesday in Stockholm.

  • July 29, 2025

    Ensure Energy Tax Credit Limit On Foreign Cos., Letter Says

    The U.S. Department of the Treasury should publish guidance aimed at preventing foreign corporations from circumventing the new budget law's limits on energy tax credits by starting construction before the restrictions kick in, a solar technology and manufacturing company said in a letter Tuesday.

  • July 29, 2025

    Top Int'l Trade Policy To Watch In The 2nd Half Of 2025

    Pervasive uncertainty surrounds international trade policy as the U.S. takes mercurial swings at the world with tariffs, including a quelled-for-now quasi embargo of China, and while lasting economic fallout hasn't materialized at home, partners abroad are aiming to replace reliance on the American market. Here, Law360 looks ahead at international trade policy during the latter half of one of the most consequential years in the field's history.

  • July 29, 2025

    Trump Says Britain's Tax On North Sea Oil 'Makes No Sense'

    President Donald Trump criticized Tuesday the British government's 78% taxes on North Sea oil as a policy that "makes no sense," a day after speaking with Prime Minister Keir Starmer about trade and other issues.

  • July 29, 2025

    Ex-IRS Acting Commissioner Joins KPMG's DC Office

    A former senior Internal Revenue Service employee who served as the agency's acting commissioner this year has joined KPMG LLP's Washington national tax practice as a senior managing director, the firm announced.

  • July 29, 2025

    Switzerland Signs Tax Treaty Update With Belgium

    Switzerland reached an agreement with Belgium to add an anti-abuse clause focused on the primary purpose of transactions to the countries' tax treaty while similar changes to the Serbian-Swiss treaty have come into force, the Swiss finance ministry said Tuesday.

  • July 28, 2025

    New IRS Chief Rejects 'Wizard Of Oz'-Style Leadership

    New Internal Revenue Commissioner Billy Long vowed Monday to engage more directly with agency employees to improve taxpayer service, emphasizing that he does not want to be a "Wizard of Oz"-style leader hiding behind a curtain.

  • July 28, 2025

    EU, US Agree To 15% Tariff Rate For Most Sectors

    The European Union and the U.S. government have reached a deal for a 15% U.S. tariff rate on EU goods from most industry sectors, including cars, semiconductor chips and pharmaceuticals, avoiding the 30% rate that was due to take effect next month.

  • July 28, 2025

    US, Japanese Businessman Settle $11.6M FBAR Dispute

    A Japanese businessman and the federal government have settled their $11.6 million tax filing dispute after the man claimed a language barrier was to blame and the U.S. tried to push past a jury's verdict, according to a Hawaii federal court filing.

  • July 28, 2025

    Britons Fear Impact Of Inheritance Tax Change On Pensions

    Four out of 10 people in Britain are concerned about the government's decision to bring pensions within the scope of inheritance tax, according to a survey by a consultancy on Monday.

  • July 25, 2025

    Trump Trade Deals Do Little To Ease Importers' Concerns

    President Donald Trump's recently announced framework trade deals offer new insight into tariff rates for several countries come Aug. 1, but experts say unanswered questions about those agreements and others still at large continue to stifle longer-term planning, leaving importers in uncertain territory.

  • July 25, 2025

    Ex-Credit Suisse Client Gets 2½ Years For Hiding Assets

    A Florida federal judge on Friday sentenced a Colombian-American businesswoman and former Credit Suisse client to two and a half years in prison for conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.

  • July 25, 2025

    Russia Loses Bid To Nix Enforcement Of $63B Awards

    A Singapore court on Friday denied Russia's bid to dodge litigation seeking the enforcement of more than $63 billion in arbitral awards issued to former investors in Yukos Oil Co. 11 years ago, rejecting the Kremlin's argument that it never agreed to arbitrate the dispute.

  • July 25, 2025

    Top International Tax Policy To Watch In 2nd Half Of 2025

    The attempt by the U.S. to win an exemption for its companies from the 15% global minimum tax is the most consequential saga currently in international tax policy, but the tumultuous trade scene and anticipated guidance on Congress' tax code tinkering are also in the minds of tax professionals. Here, Law360 looks at what further changes are likely in the volatile global tax landscape during the second half of the year.

  • July 25, 2025

    Swiss Withholding Tax Counts For Minimum Tax, Gov't Says

    Swiss multinational businesses will need to take into account Swiss withholding taxes on distributions to owners when calculating liabilities for the domestic component of the 15% global minimum tax, but not taxes paid on those distributions abroad, the Federal Tax Administration said in guidance.

  • July 25, 2025

    Rising Star: Gibson Dunn's Michael Q. Cannon

    Michael Q. Cannon of Gibson Dunn & Crutcher LLP has been the lead attorney on several high-profile cases, including playing a key role in advising on the tax aspects of the world's largest merger and acquisition deal in 2023, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 25, 2025

    IRS Provides Guidance Meant To Speed Up Corporate Audits

    The Internal Revenue Service released guidance Friday that aims to make audits more efficient for corporate taxpayers, including by phasing out a document request process taxpayers had criticized as time-consuming and of little value.

Expert Analysis

  • What's Ahead As Transparency Act Comes To A Crossroads

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    Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.

  • 7 Ways 2nd Trump Administration May Affect Partner Hiring

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    President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.

  • E-Discovery Quarterly: Rulings On Custodian Selection

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    Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.

  • Exploring Venue Strategy For Trump-Era Regulatory Litigation

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    Litigation will likely play a prominent role in shaping policy outcomes during the second Trump administration, and stakeholders have several tools at their disposal to steer regulatory litigation toward more favorable venues, say attorneys at Covington.

  • An Associate's Guide To Career Development In 2025

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    As the new year begins, associates at all levels should consider establishing career metrics, fostering key relationships and employing other specific strategies to help move through the complexities of the legal profession with confidence and emerge as trailblazers, say EJ Stern and Amanda George at Fractional Law Firm.

  • Making The Pitch To Grow Your Company's Legal Team

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    In a compressed economy, convincing the C-suite to invest in additional legal talent can be a herculean task, but a convincing pitch — supported by metrics and cost analyses — may help in-house counsel justify the growth of their team, say Elizabeth Smith and Roger Garceau at Major Lindsey.

  • Tax Court Should Update Framework For Defining Insurance

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    ​​​​​​​The U.S. Tax Court's unnecessary determination in Royalty Management Insurance v. Commissioner that a fraudulent transaction did not contain the hallmarks of a legitimate insurance transaction applies an outdated analysis that threatens the captive insurance sector and illustrates the need for a more modern framework to define true insurance, says Matthew Queen at the Queen Firm.

  • When US Privilege Law Applies To Docs Made Outside The US

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    As globalization manifests itself in disputes over foreign-created documents, a California federal court’s recent trademark decision illustrates nuances of both U.S. privilege frameworks and foreign evidentiary protections that attorneys must increasingly bear in mind, say attorneys at Hunton.

  • Impact Of Corporate Transparency Act Ambiguity On Banks

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    Even though banks generally needn't file beneficial ownership information reports, financial institutions must continue to monitor the status of the Corporate Transparency Act and understand its requirements in case the nationwide injunction that was issued against the CTA earlier this month is overturned, say attorneys at Armstrong Teasdale.

  • 6 Changes I Would Make If I Ran A Law School

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    Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.

  • Firms Still Have The Edge In Lateral Hiring, But Buyer Beware

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    Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.

  • Think Like A Lawyer: 1 Type Of Case Complexity Stands Out

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    In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.

  • Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity

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    Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.

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