International
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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.
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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.
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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.
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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.
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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.
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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).
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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.
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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.
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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.
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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%.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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Evaluating The Current State Of Trump's Tariff Deals
As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.
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How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.
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Preserving Refunds As Tariffs Await Supreme Court Weigh-In
In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.
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Writing Musicals Makes Me A Better Lawyer
My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.
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Adapting To Private Practice: From Va. AUSA To Mid-Law
Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.
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7 Document Review Concepts New Attorneys Need To Know
For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.
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Agentic AI Puts A New Twist On Attorney Ethics Obligations
As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.
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Opportunity Zone's Future Corp. Tax Benefits Still Uncertain
Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.
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How GILTI Reform Affects M&A Golden Parachute Planning
Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.
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Demystifying The Civil Procedure Rules Amendment Process
Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.
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Parenting Skills That Can Help Lawyers Thrive Professionally
As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.
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Trump Tax Law's Most Impactful Energy Changes
The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.
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Adapting To Private Practice: From Texas AUSA To BigLaw
As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.