International

  • July 22, 2025

    OECD Updates Transfer Pricing Profiles For 12 Countries

    The OECD updated 12 countries' entries in its transfer pricing database Tuesday, showing that while none of these countries has adopted the simplified approach for addressing baseline marketing and distribution activities known as Amount B, many have reached a political agreement on the measure.

  • July 22, 2025

    US Expatriations Over 1,000 Again In 2nd Quarter

    While about 200 fewer people expatriated from the U.S. in the second quarter of 2025 compared with the first quarter, the number still totaled above 1,000, the Internal Revenue Service said Tuesday.

  • July 22, 2025

    Gov't Sets Out Plan To Include Pensions In Inheritance Tax

    The government has confirmed that it is pushing ahead with plans to apply inheritance tax to wealth transferred through pensions in a move that experts say marks a "seismic" change for the sector.

  • July 21, 2025

    Guinea Tells DC Circ. $22M Award Can't Be Enforced

    The Republic of Guinea has urged the D.C. Circuit not to revive a consulting company's bid to enforce a $22 million arbitration award, saying a lower court correctly found that it was unclear whether the country agreed to arbitrate the dispute in the first place.

  • July 21, 2025

    Tax-Lien Biz Atty Tells Jury He Didn't Seek To Dupe Lender

    Counsel for a former compliance lawyer accused of pilfering from a $20 million line of credit extended to his tax-lien investment firm told a Manhattan federal jury Monday that the defendant was "sloppy," but never intended fraud.

  • July 21, 2025

    Rising Star: Davis Polk's Aliza Slansky

    Aliza Slansky of Davis Polk & Wardwell LLP is lead counsel in Sycamore Partners' $23 billion acquisition of Walgreens Boots Alliance and advised Missouri tech company Emerson on a series of multibillion-dollar sales, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 21, 2025

    UK Co. Faces £1M Penalty For Failing To Report Tax Scheme

    HM Revenue & Customs was right to determine that a company had promoted a contractor loan tax scheme, a London tribunal ruled, finding the Manchester-based business liable for up to £1 million ($1.3 million) in penalties.

  • July 21, 2025

    Strict Construction Rules Could Gut Solar, Wind Credits

    The U.S. Treasury Department could severely weaken the availability of the solar and wind energy tax credits that were scaled back under Republicans' new budget law with upcoming guidance that may upend long-standing construction rules used to determine eligibility.

  • July 21, 2025

    Family Claims Bad Tax Advice Led To Costly HMRC Bills

    The trustees of family trusts accused a U.K. accounting firm of giving them negligent advice that led to unexpected inheritance taxes and penalties owed to HM Revenue & Customs, according to a claim filed in a London court.

  • July 21, 2025

    UK Launches Online Service Available For 35M Taxpayers

    HM Revenue & Customs launched an online Pay As You Earn portal Monday, available to 35 million U.K. taxpayers, that the British revenue agency said is intended to make it easier to check on tax information as part of HMRC's overall digital transformation.

  • July 21, 2025

    Paul Hastings Boosts Tax Team In NY With Ex-Kirkland Atty

    Paul Hastings LLP announced Monday that a former Kirkland & Ellis LLP attorney is bringing her tax practice to its New York office in a move the firm says will bolster its ability to guide clients through complex deals like mergers, acquisitions and private equity transactions.

  • July 18, 2025

    Law360 Names 2025's Top Attorneys Under 40

    Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age.

  • July 18, 2025

    Trade Legal Matters To Watch: Midyear Report

    Aggressive, sweeping tariff actions have defined the first six months of President Donald Trump's second term, altering the global trade environment in attempts to return manufacturing to the U.S. and reset trading deficits, but legal challenges to certain duties may obstruct Trump's long-term trade strategy in ongoing negotiations later this year.

  • July 18, 2025

    HMRC Urged To Broaden Reporting Of Uncertain Tax Positions

    HM Revenue & Customs may need to change its rules for when taxpayers must disclose uncertain tax positions they've taken to the tax authority, according to a report by a nonprofit research organization.

  • July 18, 2025

    IRS Offers Guidance On Use Of Transfer Pricing Exception

    Taxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday.

  • July 18, 2025

    Trump Asks Supreme Court To Decline Early Tariff Challenge

    President Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts.

  • July 18, 2025

    Western Union Says IRS Used Flawed Rule To Hike Income

    The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.

  • July 18, 2025

    Taxation With Representation: Wachtell, Slaughter And May

    In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.

  • July 18, 2025

    European Tax Policy To Watch In 2nd Half Of 2025

    The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months.

  • July 18, 2025

    EU To Make Foreign Traders Liable For VAT On Imports

    Foreign companies, rather than consumers, will become liable for value-added tax on imports to the European Union beginning July 2028 under a directive adopted Friday by the bloc's council of member states, according to a news release.

  • July 18, 2025

    Oman, Trinidad And Tobago 'Largely Compliant,' OECD Says

    Reviews of the implementation of tax transparency measures in Oman and in Trinidad and Tobago found both nations "largely compliant" with Organization for Economic Cooperation and Development standards, the OECD said Friday.

  • July 17, 2025

    Canada Mulling Changes To Ability To Rewrite Transactions

    Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.

  • July 17, 2025

    US Negotiating Global Min. Tax Carveout Accord, Official Says

    The U.S. hasn't yet secured an agreement with other countries to exempt its companies from the international parts of the 15% global minimum tax despite reaching an "understanding" with the Group of 7 nations, but wider negotiations have begun, a U.S. Treasury Department official said Thursday.

  • July 17, 2025

    EU Warns Dutch Over Tax Breaks Favoring Foreign Investment

    The Netherlands may have to face the Court of Justice of the European Union if it does not amend a tax measure that provides incentives for investment in foreign companies over domestic businesses, the European Commission announced Thursday.

  • July 17, 2025

    EU Lawmakers Push For Tax Data Hub To Combat Evasion

    Members of the European Parliament approved proposals for tax changes across the European Union, including a tax data hub to streamline compliance across the bloc and help combat tax avoidance and evasion.

Expert Analysis

  • 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.

  • Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example

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    Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.

  • Accountant-Owned Law Firms Could Blur Ethical Lines

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    KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.

  • AI Will Soon Transform The E-Discovery Industrial Complex

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    Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.

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