International

  • December 23, 2025

    IRS Issues FAQs For Interest Expense Deduction Limits

    The Internal Revenue Service issued answers Tuesday to a set of frequently asked questions related to interest expense deduction calculations that were changed under the budget reconciliation law.

  • December 23, 2025

    The Biggest UK Commercial Fraud Cases In 2025

    Denmark's stinging defeat in a £1.4 billion ($1.9 billion) tax fraud claim and a U.K. Supreme Court ruling that widens the net for individuals who facilitate fraud are among the defining moments in the biggest commercial fraud cases of 2025.

  • December 22, 2025

    10th Circ. Tosses Plumbing Co.'s Captive Deduction Bid

    The Tenth Circuit is not the proper forum for a Utah plumbing company to challenge the Internal Revenue Service's 2016 notice denying a microcaptive insurance deduction, the appeals court found Monday, citing two statutes that bar the company's arguments.

  • December 22, 2025

    Draft House Bill Would Clarify Tax Rules For Digital Assets

    A bipartisan draft bill in the U.S. House would modernize the federal tax code for digital assets, its backers said, by establishing a "commonsense tax treatment" for regulated payment stablecoins, clarifying source-of-income rules for trading and extending existing securities-lending rules to digital assets.

  • December 22, 2025

    Top Federal Tax Policies Of 2025

    The first year of President Donald Trump's second term brought the passage of this summer's budget reconciliation bill, which renewed major parts of the 2017 Tax Cuts and Jobs Act, and major staffing changes at the Internal Revenue Service. Here, Law360 looks at the most consequential developments in federal tax policy in 2025.

  • December 22, 2025

    Tariff Refunds Would Be 'A Mess,' Economic Official Says

    It would be an "administrative problem" to issue tariff refunds in the aftermath of a potential U.S. Supreme Court ruling against the White House's trade measures, a top economic policy official said.

  • December 22, 2025

    IRS Seeks Input On Updates To Voluntary Disclosure Process

    The Internal Revenue Service asked Monday for comments on a proposed change to its voluntary disclosure program that would require payment of all taxes, penalties and interest within three months after being conditionally approved for the program.

  • December 19, 2025

    EU High Court Advised To Force Portugal To Reclaim Taxes

    The European Union's top court should rule that Portugal can't allow tax enforcement proceedings to be suspended in the case of unlawful state aid granted by the Madeira Free Zone, an adviser to the court said.

  • December 19, 2025

    Trade Court Remands Canada Lumber Duty Calculation Again

    The U.S. Commerce Department again failed to sufficiently justify how it calculated a subsidy rate in an antidumping duty administrative review for a Canadian exporter of softwood lumber products, the U.S. Court of International Trade said.

  • December 19, 2025

    Taxation With Representation: Baker Botts, Morgan Lewis

    In this week's Taxation With Representation, Trump Media and Technology Group merges with fusion power company TAE Technologies, pharmaceutical company Cencora boosts its stake in cancer care company OneOncology, and Phoenix Financial partners with private equity giant Blackstone to plug billions into various credit strategies.

  • December 19, 2025

    Calif. Ex-Customs Broker Sentenced For Tax, Wire Fraud

    A California man was sentenced to 51 months in federal prison after being indicted this year on federal fraud charges and one count of tax evasion, the U.S. Department of Justice said.

  • December 19, 2025

    Polsinelli Lands Glaser Weil Tax Pro In Los Angeles

    Polsinelli PC is expanding its business team, bringing in a tax pro from Glaser Weil as a shareholder in its Los Angeles office.

  • December 18, 2025

    Czech Republic, Estonia Shift To Backing Min. Tax Deal For US

    The Czech Republic and Estonia have shifted to supporting the proposed U.S. exemption from the global minimum tax's international provisions at the global tax policymaking body hosted by the Organization for Economic Cooperation and Development, the countries' finance ministries told Law360.

  • December 18, 2025

    Australia Issues Guidance On Min. Tax For Merged Accounts

    Australia's tax authority released several guidance documents detailing how the global minimum tax interacts with separate laws on accounting consolidation for corporate groups, as well as issues related to mismatched fiscal years among constituent entities.

  • December 18, 2025

    Denmark Files To Appeal £1.4B Cum-Ex Fraud Case Defeat

    Denmark has launched its effort to revive its £1.4 billion ($1.8 billion) case over a tax fraud allegedly orchestrated by convicted hedge fund trader Sanjay Shah, according to court filings seen by Law360 Thursday.

  • December 18, 2025

    HMRC Wins Burden Of Proof Query In £54M Tax Fraud Case

    A London appeals court ruled Thursday that HM Revenue & Customs doesn't bear the burden of proof in its tax liability claim against a British businessman it alleges used a company to commit alcohol smuggling and tax evasion of over £54 million ($72.2 million), plus penalties.

  • December 17, 2025

    Court Remands Commerce Ruling On Vietnam Steel Duties

    The U.S. Department of Commerce did not properly substantiate its 2023 findings that imports of Vietnamese steel products were flouting duties imposed on South Korea, India and China, the U.S. Court of International Trade said, remanding the agency's determinations.

  • December 17, 2025

    Ex-Biden Tax Counsel To Chair Willkie Tax Resolution Team

    Willkie Farr & Gallagher LLP has hired a former senior tax counsel who worked in two Democratic presidential administrations to come on board as chair of the firm's tax resolution practice group, according to a Wednesday announcement.

  • December 17, 2025

    EU Looking To Merge Tax Directives Into Single Instrument

    The European Commission is considering consolidating the nine bloc directives on administrative taxation cooperation — which cover such areas as the Organization for Economic Cooperation and Development's global minimum tax, crypto-asset reporting and cross-border tax rulings — into one legal instrument.

  • December 17, 2025

    Treasury Issues Final Rule On BEAT For Securities Lending

    Taxpayers must determine and account for certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax, according to a final rule released Wednesday by the U.S. Department of the Treasury.

  • December 17, 2025

    EU Looks To Expand CBAM To Machinery, Other Products

    The European Union has proposed expanding its carbon border adjustment mechanism beyond basic materials to cover certain steel- or aluminum-intensive products like machinery and appliances, saying it wants to prevent spurring emissions-heavy production outside the bloc.

  • December 17, 2025

    Brazil's New Dividend Tax Rules To Impose 10% Withholding

    Dividends and profits paid by Brazilian entities to nonresidents will generally be subject to a 10% withholding tax starting in the new year, the country's revenue agency said in recent guidance, adding that 2025 distributions must be approved before the end of this year to avoid the new tax.

  • December 17, 2025

    Tax Authorities Shared Data 5,500 Times In 2024, OECD Says

    Tax authorities exchanged information on tax rulings 5,500 times last year as part of the base erosion and profit-shifting rules developed by the Organization for Economic Cooperation and Development, according to a report published Wednesday.

  • December 17, 2025

    UK Supreme Court Tosses Hotel's Atty Fee VAT Appeal

    A hotel company can't reclaim value-added tax paid on fees to lawyers and accountants as part of selling a subsidiary to finance the opening of a new hotel, the U.K. Supreme Court ruled Wednesday.

  • December 16, 2025

    Corporate Transparency Act Is Constitutional, 11th Circ. Says

    The Corporate Transparency Act is constitutional because it regulates economic activities with a substantial impact on interstate commerce and doesn't violate protections against unreasonable searches, the Eleventh Circuit said Tuesday, reversing a lower court's decision.

Expert Analysis

  • Adapting To Private Practice: From NY Fed To BigLaw

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    While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.

  • Top 3 Litigation Finance Deal-Killers, And How To Avoid Them

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    Like all transactions, litigation finance deals can sometimes collapse, but understanding the most common reasons for failure, including a lack of trust or a misunderstanding of deal terms, can help both parties avoid problems, say Rebecca Berrebi at Avenue 33 and Boris Ziser at Schulte Roth.

  • A 2-Step System For Choosing A Digital Asset Reporting Path

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    Under the Internal Revenue Service's new digital asset reporting regulation, each type of asset may have three potential reporting destinations, so a detailed testing framework can help to determine the appropriate path, says Keval Sonecha at Sonecha & Amlani.

  • How Attys Can Use A Therapy Model To Help Triggered Clients

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    Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.

  • 3 Steps For In-House Counsel To Assess Litigation Claims

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    Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.

  • IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement

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    Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.

  • Adapting To Private Practice: From DOJ Enviro To Mid-Law

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    Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.

  • Legal Ethics Considerations For Law Firm Pro Bono Deals

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    If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.

  • 10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks

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    The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.

  • Power To The Paralegals: The Value Of Unified State Licensing

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    Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.

  • 10 Soft Skills Every GC Should Master

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    As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.

  • An Unrestrained, Bright-Eyed View Of Legal AI's Future

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    Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.

  • Tracking The Evolution In Litigation Finance

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    Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.

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