International

  • 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.

  • December 16, 2025

    Developing Nations Expand Corporate Tax Breaks, OECD Says

    Low- and middle-income countries generally expanded corporate tax incentives in 2024, while some coupled those measures with tax increases, the OECD reported Tuesday.

  • December 16, 2025

    Fired Top Antitrust Official Warns Of 'Politicization'

    The former No. 2 at the U.S. Department of Justice's Antitrust Division until he was terminated this year testified Tuesday about the "politicization" of antitrust enforcement.

  • December 17, 2025

    CORRECTED: Trade Court Nixes Injunction In Trump Tariff Suit

    The U.S. Court of International Trade has denied a preliminary injunction in a suit challenging President Donald Trump's emergency tariffs after auto part retailers failed to convince the court that the relief was necessary to preserve their potential right to refunds.

  • December 16, 2025

    Morrisons Owes £17M VAT On Chicken Sales, Tribunal Rules

    A London tribunal ruled that WM Morrison Supermarkets should have paid £17 million ($22.8 million) value-added tax on rotisserie chickens because the product qualifies as "hot food."

  • December 23, 2025

    Sullivan & Cromwell Hires Kirkland Pair For London Office

    Sullivan & Cromwell LLP said Tuesday that it has hired two new partners from Kirkland & Ellis LLP in London, boosting the firm's private equity and tax capabilities as it continues to expand in the City.

  • December 15, 2025

    UK Trader Couldn't Have Known Of VAT Fraud, Court Says

    Despite its "cavalier approach to due diligence," a scrap metal trader in the U.K. couldn't have known its suppliers were engaged in value-added tax fraud, so it isn't liable for additional tax and penalties, the First-tier Tribunal Tax Chamber said in a decision.

  • December 15, 2025

    UAE Clarifies Corp. Tax Liability Calculations

    The United Arab Emirates has amended its corporate tax law to clarify certain tax liability calculations, including how to factor in credits for withholding and foreign taxes, Abu Dhabi's state news agency said Monday.

  • December 15, 2025

    Cash Withdrawn From Online Biz Taxable, Tax Court Finds

    A man who received no paycheck from the online electronics business he ran in 2012 and 2013 but used its funds to purchase luxury vehicles and help a friend should have reported those amounts as taxable income, the U.S. Tax Court held Monday.

  • December 15, 2025

    Fed. Court Asked To Block IRS' Microcaptive Reporting Rule

    A Texas federal court should vacate an IRS rule aimed at flagging potential tax avoidance by requiring companies to disclose information about their microcaptive insurance transactions because it undermines Congress' authority, according to a Texas plastics company and its microcaptive adviser.

  • December 15, 2025

    Former Montana Insurer Wants Income Exclusion

    A Montana insurance company that dissolved in 2023 is challenging the IRS' determination that transactions it engaged in with an entity on the Turks and Caicos Islands didn't actually involve insurance and therefore aren't deductible for 2021.

  • December 15, 2025

    MPs Launch Inquiry Into Large Business Tax Compliance

    HM Revenue & Customs is facing an inquiry over its handling of tax compliance among large businesses, a parliamentary committee announced.

  • December 12, 2025

    Judge Says Eaton Moved $14B Subsidiary For Tax Purposes

    A U.S. Tax Court judge said Friday that he plans to find Eaton's U.S. group transferred ownership of a $14 billion subsidiary overseas in 2012 solely to justify payment of higher interest rates and guarantee fees to the company's new Irish parent.

  • December 12, 2025

    DOJ Shake-Up Keeps Criminal Tax Meetings, Ex-Official Says

    The U.S. Department of Justice — despite recently eliminating its Tax Division as part of a broad restructuring — continues to meet with practitioners representing clients who may face federal criminal tax charges, the former division chief said Friday.

  • December 12, 2025

    IRS To Revamp Voluntary Disclosure Program

    The Internal Revenue Service will be updating a program early next year that would allow taxpayers to voluntarily report previously undisclosed income as a way to resolve their tax issues to facilitate a simpler reporting process, the agency's criminal enforcement chief said Friday.

  • December 12, 2025

    Treasury Issues Final Rules For Taxing Foreign Gov't Income

    The U.S. Treasury Department issued final regulations Friday for determining whether income of foreign governments derived within the U.S. is taxable along with proposed regulations concerning when a foreign government has effective control of a commercial entity.

  • December 12, 2025

    Taxation With Representation: Cravath, Skadden, Debevoise

    In this week's Taxation With Representation, Paramount Skydance Corp. launches a hostile bid for Warner Bros. Discovery, challenging Netflix's deal to acquire the studio and streaming business, IBM acquires data streaming company Confluent, and natural gas company Antero Resources Corp. expands via a deal with HG Energy.

Expert Analysis

  • 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.

  • E-Discovery Quarterly: The Perils Of Digital Data Protocols

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    Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.

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