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International
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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.
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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."
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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June 02, 2026
Gov't Warned On Tax Regime For Collective Pension Plans
The government should consider new tax rules to ensure new collective pension plans are a success, a consultancy warned on Tuesday.
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June 01, 2026
Int'l Tax In May: Tariff Refunds Begin, New Levies Thrown Out
The U.S. Court of International Trade held last month that the temporary tariffs imposed by President Donald Trump under Section 122 of the Trade Act are illegal, and companies saw the first refunds of the levies they were meant to replace. The European Union, meanwhile, strengthened the safeguards in the trade deal it reached with the U.S. last year. Here, Law360 looks at some of the biggest international tax developments from May.
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June 01, 2026
OECD Seeks Input On Revision To Transfer Pricing Guidelines
The OECD is looking for feedback on draft revisions to its transfer pricing guidelines that deal with intragroup services, the organization said Monday.
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June 01, 2026
Fed. Circ. Affirms Dismissal Of Turkish Steel Duty Challenges
A Federal Circuit panel affirmed three U.S. International Trade Court rulings that collectively rejected a Turkish company's attempts to escape a duty on Turkish steel, finding on Monday that the company's appeals were broadly unsupported by the statutes it cited.
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June 01, 2026
EU Readies Tax Simplification Package With R&D Allowance
The European Union is preparing a shake-up of its corporate tax rules that could slash compliance costs by €7 billion ($8.15 billion) annually, according to an EU draft proposal seen by Law360 on Monday.
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June 01, 2026
EU Tax Gaps Push Company Cars Toward Petrol, Group Says
Two-thirds of European Union member states are not giving businesses a strong tax incentive to transition to using electric vehicles as company cars, according to an advocacy group.
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May 29, 2026
Expat Ordered Arrested For Skipping $20M FBAR Hearing
A Florida federal judge ordered the arrest of an expatriate U.S.-German citizen for failing to appear at a hearing to discuss civil sanctions over his failure to pay a nearly $20 million tax judgment for not disclosing foreign bank accounts.
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May 29, 2026
Canada Tax Court Rejects Gov't Stance In Bank Dividend Fight
The Tax Court of Canada agreed with two major banks that the Canadian government improperly raised a new issue in responding to their cases challenging the denial of dividends-received deductions, axing parts of the government's replies and refusing to winnow the banks' arguments.
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May 29, 2026
Taxation With Representation: Latham, White & Case, Vischer
In this week's Taxation With Representation, Fertitta Entertainment acquires Caesars Entertainment, Eli Lilly and Co. buys three companies involved in vaccine development, and nuclear energy company Newcleo Ltd. says it plans to go public by merging with a special purpose acquisition company, NewHold Investment Corp. III.
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May 29, 2026
Foreign Gov't Income Regs Aren't Retroactive, Treasury Says
The U.S. Treasury Department published guidance Friday clarifying that 2025 proposed rules regarding foreign sovereign wealth fund investment in the U.S. would not apply retroactively to the existing holdings of foreign governments.
Expert Analysis
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8 Ways Lawyers Can Protect The Rule Of Law In Their Work
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.
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Law School's Missed Lessons: Communicating With Clients
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.
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Navigating Antitrust Risks When Responding To Tariffs
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.
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Key Points From HMRC's Tax Reform Proposals
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.
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Adapting To Private Practice: From US Rep. To Boutique Firm
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.
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IRS Should Work With Industry On Microcaptive Regs
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.
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What To Note As UK Adopts OECD Crypto Disclosure Rules
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.
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Senate's 41% Litigation Finance Tax Would Hurt Legal System
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.
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
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.
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Move Beyond Surface-Level Edits To Master Legal Writing
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.
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9th Circ. Has Muddied Waters Of Article III Pleading Standard
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.
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How AI May Reshape The Future Of Adjudication
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.
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When Legal Advocacy Crosses The Line Into Incivility
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.