International
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February 10, 2026
Gov'ts Want Varied Nexus In UN Treaty's Services Protocol
Business models should have different nexus rules that don't rely on physical presence in the protocol on cross-border services under the United Nations framework convention on international tax cooperation, governments said Tuesday.
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February 10, 2026
DOJ Drops Bid For Offshore Asset Freeze In $28M Tax Suit
The U.S. Department of Justice and a family of overseas-trust beneficiaries struck a partial deal in a $28 million tax suit in Florida federal court, with the DOJ dropping its push to freeze the family's assets and the family agreeing to temporarily limit their account withdrawals.
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February 10, 2026
Ex-Clifford Chance Pro Says £8M Libel Claim Is SLAPP
Legal commentator Dan Neidle asked a court on Tuesday to use new powers to throw out an £8 million ($11 million) libel claim accusing the former Clifford Chance partner of engaging in a vendetta against a barrister, arguing that the claim was launched to silence him.
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February 09, 2026
Gov'ts Back UN Treaty's Services Protocol Covering DSTs
All income taxes and digital services taxes should be covered by the protocol on cross-border services under the United Nations framework convention on international tax cooperation, many governments said Monday during negotiations regarding the protocol.
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February 09, 2026
DOD Employee Denies Laundering Millions For Scammers
A U.S. Department of Defense logistics specialist pled not guilty Monday to federal charges accusing him of laundering millions as part of an alleged Nigeria-based fraud scheme that targeted victims in the United States.
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February 09, 2026
$19M In Foreign Account Penalties Required Jury, Court Told
A U.S.-German citizen who failed to report his foreign accounts to the IRS told a Florida federal court that his $19 million punishment violates his right to a jury trial under a U.S. Supreme Court ruling that curbed the use of in-house agency courts to hand down stiff penalties.
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February 09, 2026
€306M Money Laundering Network Sting Leads To 13 Arrests
Law enforcement agencies in the European Union have arrested more than a dozen people in several raids after an investigation into a €306 million ($364.5 million) international money laundering scheme with links to drug trafficking and tax fraud.
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February 08, 2026
DOJ Drops Challenge To AbbVie's $1.6B Break Fee Deduction
The U.S. Department of Justice agreed to stop fighting a key U.S. Tax Court ruling that allowed pharmaceutical giant AbbVie to claim a $1.6 billion termination fee to an Irish biotechnology company as an ordinary tax deduction, according to a filing in the Seventh Circuit.
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February 08, 2026
HMRC Nets £246M In Evasion-Focused Inheritance Tax Probes
Britain's tax authority has recovered an additional £246 million ($336 million) in inheritance tax secured by investigations, according to data released Sunday.
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February 06, 2026
4 Takeaways From The EU's Latest Trade Agreements
The European Union recently cemented formal trade agreements with India and Mercosur, a group of Latin American countries, which — along with creating certainty for businesses in the regions — strike a sharp contrast with the approach taken in framework deals reached by President Donald Trump. Here, Law360 examines four takeaways from the two trade agreements announced by the EU.
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February 06, 2026
Trump Orders 25% Tariff For Countries With Biz Ties To Iran
President Donald Trump signed an executive order Friday afternoon that threatens a 25% tariff on the imports entering the U.S. of countries found to be purchasing goods or services from Iran.
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February 06, 2026
Partnership Asks Justices To Restore $23M Loss Deduction
A partnership asked the U.S. Supreme Court to revive its $23 million loss deduction involving a Brazilian company, saying in a petition docketed Friday that the Second Circuit wrongly blocked a key argument and that an IRS anti-abuse regulation applied against the partnership should be invalidated.
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February 06, 2026
Gov'ts Want Safeguards For Tax Data Swaps In UN Pact
The United Nations' framework convention on international tax cooperation must ensure that exchanges of taxpayer information take place only when the information is foreseeably relevant to the requesting government's enforcement of tax laws, several representatives said Friday during negotiations.
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February 06, 2026
Buchanan Ingersoll Adds 2 Veteran Tax Pros In DC
Buchanan Ingersoll & Rooney PC has expanded its tax offerings in the nation's capital with two attorneys, including the former co-chair of the tax and private wealth practice at Whiteford Taylor & Preston LLP.
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February 06, 2026
Gunster Brings On Longtime Tax Law Professor In Florida
Florida business law firm Gunster has added an experienced tax law professor to its ranks as of counsel.
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February 06, 2026
Taxation With Representation: Gibson Dunn, S&C, Wachtell
In this week's Taxation With Representation, Elon Musk announces SpaceX's acquisition of his artificial intelligence company xAI, Devon Energy and Coterra Energy agree to merge, and Banco Santander SA acquires Webster Financial Corp.
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February 06, 2026
CPAs Suggest Treasury Scrap Doc Plans For CFC Rules
The U.S. Treasury Department should rethink planned documentation requirements for overseas income allocations, the American Institute of Certified Public Accountants recommended in a letter released Friday, saying the rules may be unnecessarily burdensome.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave
The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.
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AI Evidence Rule Tweaks Encourage Judicial Guardrails
Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.
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The Law Firm Merger Diaries: Getting The Message Across
Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.
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Horizontal Stare Decisis Should Not Be Casually Discarded
Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.
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10 Commandments For Agentic AI Tools In The Legal Industry
Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.
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The Law Firm Merger Diaries: How To Build On Cultural Fit
Law firm mergers should start with people, then move to strategy: A two-level screening that puts finding a cultural fit at the pinnacle of the process can unearth shared values that are instrumental to deciding to move forward with a combination, says Matthew Madsen at Harrison.
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Rare Tariff Authority May Boost US Battery Manufacturing
Finalizing preliminary tariffs on active anode material from China — the result of a rare exercise of statutory authority finding that foreign dumping hampered the development of a nascent U.S. industry — should help domestic battery manufacturing, but potential price increases could discourage related clean-energy use, say attorneys at MoloLamken.
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Considerations When Invoking The Common-Interest Privilege
To successfully leverage the common-interest doctrine in a multiparty transaction or complex litigation, practitioners should be able to demonstrate that the parties intended for it to apply, that an underlying privilege like attorney-client has attached, and guard against disclosures that could waive privilege and defeat its purpose, say attorneys at DLA Piper.
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The Law Firm Merger Diaries: Making The Case To Combine
When making the decision to merge, law firm leaders must factor in strategic alignment, cultural compatibility and leadership commitment in order to build a compelling case for combining firms to achieve shared goals and long-term success, says Kevin McLaughlin at UB Greensfelder.
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What To Watch As NY LLC Transparency Act Is Stuck In Limbo
Just about a month before it's set to take effect, the status of the New York LLC Transparency Act remains murky because of a pending amendment and the lack of recent regulatory attention in New York, but business owners should at least prepare for the possibility of having to comply, says Jonathan Wilson at Buchalter.
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Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar
Deputy Attorney General Todd Blanche’s recent suggestion that the D.C. Bar would be prevented from reviewing misconduct complaints about U.S. Department of Justice attorneys runs contrary to federal statutes, local rules and decades of case law, and sends the troubling message that federal prosecutors are subject to different rules, say attorneys at HWG.
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8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright
The Eighth Circuit’s recent decision invalidating transfer pricing regulations in 3M Co. v. Commissioner may be the most significant tax case implementing Loper Bright's rejection of agency deference as a judicial tool in statutory construction, says Edward Froelich at McDermott.
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Rule Amendments Pave Path For A Privilege Claim 'Offensive'
Litigators should consider leveraging forthcoming amendments to the Federal Rules of Civil Procedure, which will require early negotiations of privilege-related discovery claims, by taking an offensive posture toward privilege logs at the outset of discovery, says David Ben-Meir at Ben-Meir Law.