International

  • June 05, 2026

    Abbott Says Timing Mismatch Lets $8B Gain Go Untaxed

    Abbott Laboratories asked the U.S. Tax Court to find that it needn't recognize an $8 billion gain in 2020 from transactions between several of its controlled foreign corporations because of a mismatch in the effective dates of different sections of the 2017 U.S. Tax Cuts and Jobs Act.

  • June 05, 2026

    HMRC's Reading Would Double-Tax £10M, Upper Tribunal Told

    Shareholders of a holding company argued before the Upper Tribunal on Friday that HM Revenue & Customs misinterpreted tax legislation, risking the same £10 million ($13.4 million) in payouts being taxed twice after a capital reduction.

  • June 05, 2026

    Taxation With Representation: Simpson Thacher, Fried Frank

    In this week's Taxation With Representation, Berkshire Hathaway Inc. takes Taylor Morrison Home Corp. private, global real estate investment company Kennedy Wilson forms a residential joint venture with Netherlands pension services provider APG, and Wellington Management acquires Hartford Funds from insurer The Hartford.

  • June 05, 2026

    Wife Of Bankrupt Former EY Tax Chief Sued By Trustees

    The bankruptcy trustees of former EY head of tax John Dixon are bringing a claim against his wife, according to a newly public entry on the High Court's filing system.

  • June 05, 2026

    Irish Presidency Outlines Forecast For EU Tax Info Shake-Up

    The incoming Irish presidency of the Council of the European Union outlined predictions for EU tax changes — including some related to information sharing — in a note to policy experts seen by Law360 on Friday.

  • June 04, 2026

    Feds Appeal Trade Court's Emergency Tariff Refund Order

    The federal government has appealed the U.S. Court of International Trade's order requiring refunds on all duties paid under the International Emergency Economic Powers Act after the U.S. Supreme Court struck them down this year, according to filings in the trade court and Federal Circuit.

  • June 04, 2026

    HMRC Defends Tax Win In £10M Share Payout Dispute

    The U.K.'s tax authority told a London court Thursday that a shareholder payout falls within anti-tax avoidance rules in a case concerning the tax treatment of £10 million ($13.4 million) in shares paid out following a capital reduction.

  • June 04, 2026

    Ex-Surgeon Agrees To $7.7M Tax Bill From Offshore Scheme

    A retired plastic surgeon reached a $7.7 million settlement with the federal government to resolve an Internal Revenue Service case alleging that he ran an offshore employee leasing scheme, according to an agreement filed in an Ohio federal court.

  • June 04, 2026

    EU Tobacco Tax Bill Dropped From Upcoming Negotiations

    Ambassadors from European Union countries failed to reach an agreement on a controversial EU tobacco taxation bill, according to an EU official, meaning the file has been withdrawn from the agenda of an upcoming meeting of member state finance ministers.

  • June 04, 2026

    EU Calls On Germany, Poland, Spain To Correct Tax Policies

    The European Union's executive branch has called on Germany, Poland and Spain to end tax policies that it has determined violate the bloc's rules.

  • June 04, 2026

    OECD Urges Nations to Mull Tax Breaks In Pillar 2 Safe Harbor

    Countries should "think carefully" about how their tax incentives will fit into a side-by-side safe harbor under the 15% global minimum corporate tax known as Pillar Two, the Organization for Economic Cooperation and Development said in a report released Thursday.

  • June 04, 2026

    HMRC Arrests Two Over Suspected £153M TikTok Tax Scam

    The tax authority said Thursday that it had arrested two men suspected of using TikTok to perpetrate an alleged multi-million-pound tax fraud by persuading users to hand over tax account details with the promise of "quick cash."

  • June 03, 2026

    Texas Instruments Defends Deductions For Exercised Options

    Texas Instruments challenged total deficiencies of $47.9 million for 2018 and 2019, much of it from the IRS' disallowance of deductions for deferred compensation, such as exercised stock options, under an approach consistent with a 2022 agency advice memorandum.

  • June 03, 2026

    UK Adults Unaware Of Inheritance Tax Relief, Insurer Says

    Almost three-quarters of British adults don't know that certain gifts are exempt from inheritance tax as the fiscal rules for estates and pensions are set to change in April 2027, according to research published Wednesday.

  • June 03, 2026

    USTR Floats Double-Digit Tariffs On Basis Of Forced Labor

    Sixty economies are facing added tariffs of either 10% or 12.5% on their exports to the U.S. following investigations by the U.S. Trade Representative's Office into countries' protections against the importing of goods produced with forced labor.

  • June 03, 2026

    Iran War Driving Slower Growth, Surging Inflation, OECD Says

    The Iran war is driving slower growth and surging inflation across the global economy, and U.S. tariff policy is adding to uncertainty, the OECD said Wednesday during a virtual news conference.

  • June 03, 2026

    USTR Seeks Input On China Preferential Trade Mechanism

    The Office of the U.S. Trade Representative announced what it is calling a government-to-government mechanism that will manage bilateral trade between the U.S. and China, including by considering tariff cuts, and asked for public comments on the program's development.

  • June 03, 2026

    Australia Considers Floating Tax Whistleblower Rewards

    The Australian Treasury is seeking feedback on its tax whistleblowing framework, including whether the regime should offer financial incentives for exposing misconduct and whether current rules effectively protect those who already do.

  • June 03, 2026

    EU Court Upholds Denial Of Late VAT Correction

    European Union law on value-added tax does not prevent member states from restricting VAT corrections after the closure of an audit period, an EU court said Wednesday, provided that the taxpayer had a reasonable opportunity to correct the submission before the deadline.

  • June 02, 2026

    Brazil Facing 25% US Tariff Over IP, Other 'Unfair Practices'

    The U.S. Trade Representative proposed hitting Brazil with a broad 25% tariff following a trade investigation that it says uncovered a slew of "unfair practices that imposed burdens on American businesses," including poorly enforced intellectual property rights and preferential tariffs.

  • June 02, 2026

    US Pushes To Keep Trump Tariffs In Effect During Appeal

    The Federal Circuit should maintain a pause on a lower court's order blocking President Donald Trump's temporary global tariffs with respect to Washington state and two businesses, the U.S. argued, saying the merits "lopsidedly" favor a stay during the government's appeal.

  • June 02, 2026

    Fennemore Craig Builds Calif. Presence With Boutique Tie-Up

    Fennemore Craig PC has launched its 24th office with the addition of a 15-person team of attorneys and legal professionals from Northern California boutique Reynolds Law LLP.

  • June 02, 2026

    HMRC Should Extend Tax Filing Pilot, Industry Groups Say

    Britain's tax authority should extend the time for a pilot of a standardized corporate tax filing system for more than 3 million companies, two industry groups said Tuesday.

  • June 02, 2026

    EU Parliament Trade Committee Advances US Trade Deal

    With a July 4 deadline set by President Donald Trump looming, the European Union moved one step closer to implementing its trade deal cutting tariffs — though with added guardrails — as a Parliament committee voted Tuesday to advance the legislation.

  • June 02, 2026

    EU Says Blocwide Digital Tax Could Bring In €5B Per Year

    The European Union estimates that a 3% tax on digital services in the region could bring in €5 billion ($5.8 billion) annually for the bloc's budget, according to a European Commission document seen by Law360 on Tuesday.

Expert Analysis

  • 8 Ways Lawyers Can Protect The Rule Of Law In Their Work

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    Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.

  • Law School's Missed Lessons: Communicating With Clients

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    Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

  • Navigating Antitrust Risks When Responding To Tariffs

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    Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.

  • Key Points From HMRC's Tax Reform Proposals

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    Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • What To Note As UK Adopts OECD Crypto Disclosure Rules

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    With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

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