International
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January 12, 2026
India High Court Rules Post-Merger Shares Can Be Taxed
The Supreme Court of India ruled that if companies combine to create a new business with shares that are worth more than those of the individual corporations, investors may owe taxes on the difference in value.
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January 12, 2026
OECD Issues Guidance On Real-Time Reporting For VAT
The OECD has released guidance for policymakers on designing mandates for real-time reporting of transactions to tax authorities for value-added tax purposes, which are increasingly being considered and adopted by countries worldwide.
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January 09, 2026
US Disputes Right To Trial Before IRS Assesses FBAR Fines
A California man wasn't entitled to a jury trial prior to the IRS assessing penalties for his failure to report foreign bank accounts because the U.S. Supreme Court decision he cited limiting administrative courts for securities fraud doesn't apply, the government told a California federal court.
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January 09, 2026
EU Council Approves Trade Pact With 4 S. American Countries
A legislative arm of the European Union approved the bloc's free trade agreement with four South American countries Friday, taking steps to create the largest global free trade zone.
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January 09, 2026
Taxation With Representation: King & Spalding, Torys, Milbank
In this week's Taxation With Representation, power generation company Vistra Corp. acquires Cogentrix Energy from Quantum Capital Group, real estate firm Minto Group partners with Crestpoint Real Estate Investments to take Minto's apartment-focused real estate investment trust private, and engineering services provider Jacobs acquires a remaining stake in PA Consulting.
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January 09, 2026
China To Cut VAT Export Tax Rebates For Solar Panels
China will eliminate its value-added tax export rebates for photovoltaic and other related products starting April 1, the country's Ministry of Finance said Friday.
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January 09, 2026
UK Gov't Rules Out Farm Inheritance Tax Concessions
The U.K.'s Labour government will not make more concessions to farmers on its inheritance tax rule changes for agricultural land after a recent compromise on the tax threshold, a minister said in a speech at a conference.
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January 08, 2026
OECD, Gov't Officials Praise 'Side-By-Side' Tax Deal
Officials from Germany, the U.S. and the OECD on Thursday hailed a recently finalized agreement among roughly 150 countries as a balanced solution to the U.S.' desire for a global minimum tax regime that operates "side by side" with its own rules.
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January 08, 2026
Courts Back Agencies Despite Loper Bright Ruling, DOJ Says
Appellate courts have mostly upheld federal agencies' interpretation of ambiguous statutes, including tax disputes, even after the U.S. Supreme Court's 2024 landmark decision that limited agency deference, a U.S. Department of Justice attorney said Thursday.
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January 08, 2026
US Asks 6th Circ. To Revive Reg In $89M FedEx Tax Suit
The Sixth Circuit should vacate a judgment that allowed FedEx an $89 million refund by discarding a regulation preventing companies from claiming foreign tax credits on earnings offset by losses, which aren't taxed in the U.S., the government said in an opening brief.
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January 08, 2026
Irish R&D Tax Credit Linked To €7B In Spending, Gov't Says
Ireland's tax credit for research and development is linked to €7 billion ($8.2 billion) in related spending by companies on the island in 2023 while costing the government about €1.4 billion, the Irish Department of Finance said Thursday.
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January 08, 2026
Data Supervisor Warns Against Exceptional VAT Info Searches
The European Union's plans to crack down on value-added tax fraud may blur the line between data cooperation and law enforcement, potentially undermining data protection, the EU's data supervisor warned Thursday.
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January 08, 2026
Audits Get Final Word On Economic Substance, IRS Atty Says
IRS attorneys provide legal guidance during audits on whether a transaction lacks economic substance, but examiners make the ultimate determination, an agency associate chief counsel said Thursday while explaining how the agency applies a powerful anti-abuse tool in audits.
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January 08, 2026
HSBC To Pay €300M To Settle French Tax Fraud Probe
HSBC has agreed to pay French authorities more than €300 million ($350 million) in fines and unpaid taxes to settle a criminal probe into how the bank's Paris branch handled dividend arbitrage transactions between 2014 and 2019, public prosecutors revealed Thursday.
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January 08, 2026
OECD Project Seeks To Ease Access To Tax Dispute Process
A new project at the OECD will aim to ensure that double-tax cases are eligible to be resolved through bilateral government negotiations under treaties no matter how they're characterized by a country's tax authority, a U.S. Treasury Department official said Thursday.
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January 07, 2026
US Official Gives Rationale For OECD Global Mobility Changes
Recent changes to the commentary on when a home office gives rise to a permanent establishment in the OECD model tax treaty reflect delegates' unhappiness with previous language on the availability of an office, a U.S. Treasury Department official said Wednesday.
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January 07, 2026
Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says
The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed Swiss account, the Second Circuit said Wednesday, upholding a lower court's judgment.
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January 07, 2026
Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies
The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025.
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January 07, 2026
Gov't Slow-Rolling Lower Fee For Expatriation, Court Told
The U.S. State Department has impermissibly slow-walked the rollout of a reduced fee for renouncing U.S. citizenship, a Paris-based group that represents Americans permanently residing abroad told a D.C. federal court.
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January 07, 2026
Australia Increasingly Blocking Tax Debtors From Leaving
The Australian Taxation Office is increasingly barring international travel for people with tax debts who it suspects of trying to flee their obligations, it said Wednesday.
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January 07, 2026
IRS Mulling Budget Bill's Changes To CFC Rules, Official Says
The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.
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January 07, 2026
Irish Tax Revenue Up €8.6B In 2025, Corp. Taxes Up 17%
The Irish government saw tax revenue rise by €8.6 billion ($10 billion) in 2025, with corporate tax receipts up by 17.2%, the Department of Finance said in its annual report.
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January 07, 2026
Portuguese Tax System Too Complex, OECD Says
The Portuguese government needs to simplify the country's tax regime to boost economic growth and raise living standards, the Organization for Economic Cooperation and Development said Wednesday.
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January 07, 2026
IRS Outlines Process For PFICs Seeking Retroactive Elections
The Internal Revenue Service set out requirements Wednesday for passive foreign investment corporations seeking rulings to allow them to make retroactive qualified electing fund elections.
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January 06, 2026
IRS Appeals Pause Of ICE Info-Sharing Agreement
The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.
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.