International

  • February 05, 2026

    Russian Scientist's US Wages Not Tax-Exempt, Tax Court Says

    The U.S. Department of Energy's payments to a Russian scientist for subatomic particle research in Virginia don't fall under a U.S.-Russia tax treaty covering tax-exempt grants, the U.S. Tax Court held Thursday.

  • February 05, 2026

    UN Talks Aim To Identify Gaps On Harmful Tax Practices

    Representatives of governments asked their colleagues Thursday to pinpoint gaps in ongoing efforts to address harmful tax practices in order to sharpen the United Nations' framework convention on international tax cooperation.

  • February 05, 2026

    Ga. Law Firm's CTA Challenge 'Hypothetical,' Feds Argue

    The U.S. Treasury Department has asked a federal judge to toss a Georgia lawyer's suit alleging that the 2021 Corporate Transparency Act could force him to violate attorney-client privilege, arguing the suit is based on future "hypothetical changes" to the federal policy of nonenforcement.

  • February 05, 2026

    Hostages Aren't Receiving Tax Relief, TIGTA Says

    Recently released hostages did not receive tax relief despite the Internal Revenue Service implementing new procedures to improve the process to provide tax relief to taxpayers wrongfully detained or taken hostage, the Treasury Inspector General for Tax Administration said in a report released Thursday.

  • February 04, 2026

    Developing Nations See Tax Data Swaps Lacking Reciprocity

    Developing countries' requests for taxpayer information are often denied by other countries even as the resource-strapped nations have invested resources in fulfilling incoming requests, government officials said Wednesday.

  • February 04, 2026

    Tax Group Of The Year: Davis Polk

    Davis Polk & Wardwell LLP scored a significant victory for Exxon Mobil in litigation concerning the tax treatment of a major partnership with Qatar and oversaw several other complex, high-stakes transactions, earning it recognition as a 2025 Law360 Tax Practice Group of the Year.

  • February 04, 2026

    IRS Urges Tax Court To Cut $315M From Siemens Deduction

    The Internal Revenue Service defended its slashing of $315 million from a tax deduction that medical giant Siemens claimed on payments from overseas, telling the U.S. Tax Court that rule writers had congressional backing to issue the regulations underpinning the adjustment.

  • February 04, 2026

    Walmart Wants Relief In CFC Tax Year Deferral

    Walmart asked the U.S. Department of the Treasury to temporarily allow certain taxpayers to file a single 13-month return, instead of two separate returns, in the wake of filing changes regarding controlled foreign corporations, according to a letter released Wednesday.

  • February 04, 2026

    One Essex Court Barrister Sued For Negligence In £32M Case

    Billionaire Michael Platt and his hedge fund have accused a One Essex Court barrister of negligence by failing to set out two key appeal arguments in a dispute with tax authorities over a £32.25 million ($44 million) charge.

  • February 03, 2026

    Dairy Co. Presses UK Court To Revive Tax Deductions On IP

    A European dairy giant asked a London appeals court on Tuesday to overturn lower tribunal rulings denying the company tax deductions for the gradual write-off of brands, intellectual property and goodwill following an acquisition.

  • February 03, 2026

    Gov'ts Resist Binding Treaty Renegotiations In UN Tax Pact

    Several governments expressed opposition Tuesday to a proposed requirement for countries to renegotiate bilateral tax treaties in line with principles aimed at fairly allocating taxing rights as part of the United Nations framework convention on international tax cooperation.

  • February 03, 2026

    IRS Floats Clean Fuel Credit Rules With Foreign Restrictions

    The Internal Revenue Service released long-awaited proposed regulations Tuesday clarifying how domestic transportation fuel producers can qualify for the clean energy fuel tax credit under changes made by Republicans' 2025 budget law, including new foreign restrictions on business owners and feedstock sources.

  • February 03, 2026

    French Gov't Approves Budget With New Corp. Tax Measures

    The French government has adopted a budget that targets wealthy people and corporations, including a surtax on the country's biggest companies that is expected to bring in €7.3 billion ($8.6 billion).

  • February 03, 2026

    Virgin Islands Co. Wants Experts Barred In $11.5M Pricing Row

    A U.S. Virgin Islands mortgage company challenging the territorial government over $11.5 million in tax bills asked a federal court Tuesday to exclude expert testimony meant to bolster the government's case that the company wrongly claimed a tax break meant to help the local economy.

  • February 03, 2026

    HMRC Disputes Danish Wind Farm's Tax Relief At Top Court

    Britain's tax authority told the U.K. Supreme Court on Tuesday that a Danish wind farm company can't claim tax relief on pre-development costs for building wind farms, because the costs are too remote from the actual provision of plants and machinery.

  • February 02, 2026

    Int'l Tax In January: Global Min. Reached, Trade Deals Abound

    January was a busy month in international tax, starting with an agreement by nearly 150 countries on a global minimum tax that effectively exempts U.S. companies and culminating with trade deals between Canada and China as well as India and the European Union. Here, Law360 looks at the biggest developments in international tax over the last month.

  • February 02, 2026

    Trump, Modi Say US-India Trade Deal Reached

    President Donald Trump said Monday he reached a trade deal with India following a call with Prime Minister Narendra Modi that includes lowering the tariff rate on Indian goods entering the U.S. from 50% to 18%.

  • February 02, 2026

    Spencer Fane Expands To New Orleans With Litigation Hire

    Spencer Fane LLP announced that an experienced Louisiana-based attorney from Phelps Dunbar LLP has joined the firm's litigation and dispute resolution team as a partner, marking the fast-growing firm's initial foray into the New Orleans market.

  • February 02, 2026

    India To Provide Tax Break For Cloud Service Providers

    India will implement several tax measures designed to attract multinational corporations, including a "tax holiday" for foreign companies that provide cloud services using the country's data services, the government announced.

  • February 02, 2026

    US Drops $185K FBAR Case Amid State Dept. Silence

    The U.S. Department of Justice dropped its case Monday accusing a U.S. citizen living in Switzerland of hiding bank accounts from the IRS, telling a D.C. federal court that the U.S. Department of State fell silent on a request for help from Swiss authorities.

  • February 02, 2026

    OECD Amends Tax Treaty Manual To Up Dispute Resolution

    The Organization for Economic Cooperation and Development is updating guidance for tax treaties to strengthen tax treaty mechanisms for preventing cross-border tax disputes, according to a statement Monday.

  • February 02, 2026

    EU Loses €14B In Taxes Annually From US Cos., Report Says

    European Union member states are losing €14 billion ($16.5 billion) in revenues each year as a result of tax avoidance by U.S. companies, Tax Justice Network warned Monday ahead of international tax talks.

  • February 02, 2026

    Norton Rose Grows In Key Cities By Adding 5 Polsinelli Attys

    Norton Rose Fulbright announced Monday that it has added five former Polsinelli PC shareholders as partners to grow its transactional and healthcare capabilities in two key U.S. markets.

  • January 30, 2026

    3 Things To Keep In Mind About IRS' Corporate Audit Changes

    The IRS' revamped audit process for corporate taxpayers will likely streamline examinations, but companies may now shoulder new responsibilities when presenting facts and face lingering uncertainties when weighing whether to participate in a broadened settlement program. Here, Law360 examines three key issues for companies to consider under the new audit process.

  • January 30, 2026

    US Rebukes WTO Siding With China On Energy Tax Credits

    The U.S. Trade Representative condemned the World Trade Organization's decision to side with China in a dispute over energy tax credits passed during former President Joe Biden's term Friday, calling the global body's dispute resolution mechanism inadequate.

Expert Analysis

  • IRS Should Revise Overbroad Microcaptive Regs

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    Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.

  • What's Next For Russia Sanctions After Task Force Disbanded

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    Attorney General Pam Bondi’s recent disbanding of Task Force KleptoCapture, which was initially aimed at seizing Russian oligarchs’ funds and assets, is unlikely to mean the end of Russia sanctions enforcement and other economic countermeasures, as the architecture for criminal enforcement remains in place, say attorneys at BakerHostetler.

  • How Law Firms Can Counteract The Loneliness Epidemic

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    The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.

  • 5 Keys To Building Stronger Attorney-Client Relationships

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    Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.

  • Attorneys Must Act Now To Protect Judicial Independence

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    Given the Trump administration's recent moves threatening the independence of the judiciary, including efforts to impeach judges who ruled against executive actions, lawyers must protect the rule of law and resist attempts to dilute the judicial branch’s authority, says attorney Bhavleen Sabharwal.

  • Rethinking 'No Comment' For Clients Facing Public Crises

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    “No comment” is no longer a cost-free or even a viable public communications strategy for companies in crisis, and counsel must tailor their guidance based on a variety of competing factors to help clients emerge successfully, says Robert Bowers at Moore & Van Allen.

  • Reading The Tea Leaves On Mexico, Canada And China Tariffs

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    It's still unclear whether the delay in the imposition of U.S. tariffs on Canadian and Mexican imports will result in negotiated resolutions or a full-on trade war, but the outcome may hinge on continuing negotiations and the Trump administration's possible plans for tariff revenues, say attorneys at Eversheds Sutherland.

  • How Design Thinking Can Help Lawyers Find Purpose In Work

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    Lawyers everywhere are feeling overwhelmed amid mass government layoffs, increasing political instability and a justice system stretched to its limits — but a design-thinking framework can help attorneys navigate this uncertainty and find meaning in their work, say law professors at the University of Michigan.

  • The Pros And Cons Of A 2nd Trump Term For UK Tech Sector

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    While U.S. President Donald Trump’s protectionist stance on trade could disrupt global supply chains on which many U.K. tech firms are reliant, anticipated deregulation could provide fertile ground for investment and growth, and the U.K. tech sector is bracing for a mix of opportunities, say lawyers at Shoosmiths.

  • Corp. Transparency Act's Future Under Treasury's Bessent

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    The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.

  • A Look At A Possible Corporate Transparency Act Exemption

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    Attorneys at Kirkland offer a deep dive into the application of the Corporate Transparency Act's reporting requirements specifically to U.S.-domiciled co-issuers in typical collateralized loan obligation transactions, and consider whether such issuers may be able to assert an exemption from the CTA's reporting requirements.

  • Inconsistent Injury-In-Fact Rules Hinder Federal Practice

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    A recent Third Circuit decision, contradicting a previous ruling about whether consumers of contaminated products have suffered an injury in fact, illustrates the deep confusion this U.S. Supreme Court standard creates among federal judges and practitioners, who deserve a simpler method of determining which cases have federal standing, says Eric Dwoskin at Dwoskin Wasdin.

  • In-House Counsel Pointers For Preserving Atty-Client Privilege

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    Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.

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