International

  • 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.

  • July 25, 2025

    6 Things To Know About Illinois' New Tax Landscape

    Illinois' latest budget has altered the state's tax system for 2025 and beyond, including by offering three tax amnesty programs, making significant changes to corporate tax law and implementing a relatively new concept for the sourcing of pass-through entity sales. Here, Law360 looks at aspects that state tax practitioners say are crucial to their clients.

  • July 25, 2025

    France Says It Will Accept Amount B Decisions

    France will accept transfer pricing decisions made under the simplified and streamlined OECD process known as Amount B, provided they're made by an eligible low-capacity country that has a bilateral tax treaty with France, the French government said.

  • July 25, 2025

    Legal Org. Urges DC Circ. To Reject Trump's Tariff Powers

    The D.C. Circuit should affirm a ruling that sided with toy makers and blocked President Donald Trump from using an international economic law to impose emergency tariffs because the law does not give the president the authority he claims, a legal organization argued.

  • July 25, 2025

    Taxation With Representation: Weil, Freshfields, Linklaters

    In this week's Taxation With Representation, CC Capital and One Investment Management acquire Insignia Financial Ltd., catering giant Compass Group PLC acquires Dutch food and hospitality company Vermaat Groep BV, drugmaker Sanofi acquires biotech company Vicebio, and The Ether Machine launches as a public company.

  • July 25, 2025

    UK Adds Spain, Guernsey To Approved Minimum Tax List

    The U.K. government added Spain and the island of Guernsey to its list of jurisdictions that have implemented the Organization for Economic Cooperation and Development's global corporate minimum tax mechanisms.

  • July 24, 2025

    EU Prepared To Impose €93B In Tariffs On US Goods

    The European Commission voted Thursday to impose tariffs on €93 billion ($109 billion) worth of U.S. goods if no trade deal is reached by August as the two sides continue negotiations.

  • July 24, 2025

    Rising Star: McDermott's Michael Bruno

    Michael Bruno of McDermott Will & Emery LLP was tapped as lead tax counsel by two legendary athletes — Lionel Messi and Stephen Curry — for the rollouts of their respective beverage brands, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.

  • July 24, 2025

    GOP Reps. Urge IRS To Roll Back Economic Substance Ruling

    The Internal Revenue Service should withdraw a revenue ruling that invokes the economic substance doctrine to disregard certain intercompany transactions, 20 Republicans on the House Ways and Means Committee said Thursday, arguing it leaves taxpayers uncertain about how to apply partnership tax laws to commercial transactions.

  • July 24, 2025

    EU Considering Overhaul Of VAT On Traveling

    The European Commission is seeking comments on how best to adjust its value-added tax rules for travel agents and passenger transportation, saying Thursday that the current rules are outdated and overly complex, leading to economic distortions and lower tax revenue.

Expert Analysis

  • A Cold War-Era History Lesson On Due Process

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    The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.

  • How BigLaw Executive Orders May Affect Smaller Firms

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    Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.

  • Lawsuits Shouldn't Be Shadow Assets For Foreign Capital

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    Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.

  • How To Accelerate Your Post-Attorney Career Transition

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    Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.

  • Tariffs And FCA Create Perfect Storm For Importers

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    The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.

  • US Reassessment Of OECD Tax Deal Is Right Move

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    The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.

  • Measuring And Mitigating Harm From Discriminatory Taxes

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    In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.

  • Adapting To Private Practice: From DOJ Leadership To BigLaw

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    The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.

  • How The CRE Industry Is Adapting To Tariff Uncertainty

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    Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.

  • Law Firm Executive Orders Create A Legal Ethics Minefield

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    Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.

  • Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike

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    The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.

  • Firms Must Embrace Alternative Billing Models Or Fall Behind

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    As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.

  • How Attorneys Can Master The Art Of On-Camera Presence

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    As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.

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