International

  • October 01, 2025

    NJ Can't Tax Sale Of Stake In Foreign Co., Enterprise Says

    Car rental giant Enterprise asked the New Jersey Tax Court to negate a $1.2 million tax assessment stemming from a sale of interest in an Israel-based software company, arguing that the gain was nonoperational income that should be allocated to Enterprise's home state, Missouri, for tax purposes.

  • October 01, 2025

    Healthcare Training Co. Says Firm's VAT Advice Cost It £2M

    An accounting firm gave incorrect advice to a healthcare worker training company on value-added tax registration, the company alleged in a claim filed with a London court, leading to a tax liability of almost £2 million ($2.7 million).

  • October 01, 2025

    Peru Says Mining Co. Can't Revive $417M Penalty Claim

    Peru is resisting an Arizona-based mining company's bid to annul a decision by international arbiters who found they lacked jurisdiction over $417 million in penalties and interest the country imposed for unpaid royalties, saying the company is wrong to claim the issue was improperly ignored.

  • October 01, 2025

    Caplin & Drysdale Adds Longtime IRS Pro To DC Office

    Caplin & Drysdale has grown its Washington, D.C., office with the addition of a veteran Internal Revenue Service attorney, the firm announced Wednesday.

  • October 01, 2025

    8th Circ. Reverses IRS Win In 3M Transfer Pricing Case

    The Eighth Circuit reversed a U.S. Tax Court ruling Wednesday that backed the Internal Revenue Service's decision to reallocate nearly $24 million of 3M Co.'s Brazilian income, holding that the transfer pricing regulations underlying the adjustment are invalid.

  • October 01, 2025

    Bank CEO Cleared Of Dishonestly Assisting £415M Tax Fraud

    A Caribbean bank and its former chief executive have been cleared of dishonestly assisting a £415 million ($558 million) value-added tax fraud as a London court ruled that he did not know about the scheme to defraud tax authorities.

  • September 30, 2025

    IRS To Rework Corporate AMT Proposed Regs

    The Internal Revenue Service plans to revise proposed regulations for the corporate alternative minimum tax, the agency announced Tuesday, including rules that would lessen businesses' compliance demands and costs tied to assessing their liability.

  • September 30, 2025

    Justices Could Enable IEEPA Taxes On Any Trade, Experts Say

    If the U.S. Supreme Court decides that a president's power to regulate imports and exports under the International Emergency Economic Powers Act encompasses tariffs, a president could tax services, investments and intellectual property flowing into or out of the country, trade experts said Tuesday.

  • September 30, 2025

    IRS Further Delays Deadlines For Victims Of Israel-Hamas War

    The Internal Revenue Service further postponed already-delayed tax return and payment deadlines that were set for Tuesday for those impacted by the Israel-Hamas war from 2023 through 2025, the agency said.

  • September 30, 2025

    IRS Penalty Case Tossed For Now Over Shifting Legal Claims

    A woman's shifting legal theories doomed her challenge to IRS penalties related to her delayed disclosure of a foreign inheritance, a California federal judge found, tossing the suit but allowing her to amend her complaint.

  • September 30, 2025

    Altria Loses Out On $38M Refund On Foreign Subsidiaries

    Tobacco products maker Altria is not entitled to a $38 million tax refund on foreign subsidiaries, a Virginia federal court found, saying the company was an indirect shareholder through its interest in Anheuser-Busch and therefore owes taxes on its portion of the subsidiaries' income.

  • September 30, 2025

    UK's Average R&D Tax Credit Claim Jumps 33%

    The U.K. has seen the average value of research and development tax credit claims rise despite the overall number of such claims falling in the last tax year, HM Revenue & Customs said Tuesday.

  • September 30, 2025

    Trump Orders Lumber, Furniture Tariffs To Begin Oct. 14

    In an executive order signed Monday evening, President Donald Trump outlined a series of tariff rates on imported lumber and derivative products to be imposed in two weeks.

  • September 30, 2025

    EU Floats Tax Incentives To Encourage Savings, Investment

    The European Commission has issued a blueprint for tax incentives and other measures to help the European Union's member states encourage their residents to set up savings and investment accounts.

  • September 29, 2025

    Tribal Members Push For Say In Supreme Court Tariff Review

    Members of the Blackfeet Nation tribe told the U.S. Supreme Court Monday their inclusion in the justices' review of suits challenging the legality of President Donald Trump's emergency tariffs is crucial to protect Native American rights under federal law.

  • September 29, 2025

    EU Council Eases Carbon Rules To Reduce Biz Burdens

    The Council of the European Union adopted measures Monday aimed at simplifying the bloc's carbon border adjustment mechanism, including exemptions for small importers.

  • September 29, 2025

    China To Require Platforms To Report Workers' Tax Data

    China's government will begin requiring online platform operators to report tax data such as income about all workers for the first time Wednesday, the State Taxation Administration said Monday.

  • September 29, 2025

    UK Wealth Tax Not Needed, Chancellor Says

    Britain doesn't need a wealth tax to cover its spending and debt commitments, Chancellor of the Exchequer Rachel Reeves said Monday.

  • September 29, 2025

    Argentina Ratifies OECD Tax Treaty Standards

    Argentina will begin to align its tax treaties with OECD standards on tax avoidance on Jan. 1, 2026, the organization said Monday after the country ratified the multilateral convention on base erosion and profit shifting.

  • September 29, 2025

    Calif. Tech Retailer Challenges $3.5M Bill In Tax Court

    A California electronics retailer is challenging a nearly $3.5 million tax bill in the U.S. Tax Court based on the company's contention that the IRS failed to recognize that a Hong Kong affiliate carried out a portion of its sales.

  • September 29, 2025

    IRS Pulls Plug On Proposed Corporate Spinoff Regulations

    Proposed regulations for a narrow set of tax-free corporate separation deals known as spinoffs and a multiyear reporting regime for those transactions will be withdrawn, the Internal Revenue Service announced Monday, citing widespread criticism of the framework proposed in January.

  • September 29, 2025

    IRS Cancels Hearing On Offshore Profit Regulations

    The Internal Revenue Service said Monday that it has canceled a public hearing on proposed rules that would require U.S. multinational corporations to create annual shareholder accounts and follow new pooling concepts to account for previously taxed foreign earnings and basis adjustments.

  • September 26, 2025

    Audits Focused On Profit Shifting, Transfer Pricing, ATO Says

    International profit shifting is the subject of about 70% of the Australian Taxation Office's ongoing income tax audits of public and multinational corporations, with transfer pricing of cross-border financing and marketing being major focuses, according to a report published Friday.

  • September 26, 2025

    Trump Announces 100% Tariff On Drug Imports Starting Oct. 1

    President Donald Trump announced a slew of new Section 232 tariffs to be imposed beginning Oct. 1, including a 100% tariff on drug imports and new rates for semi trucks, kitchen cabinets, bathroom vanities and upholstered furniture.

  • September 26, 2025

    Microsemi, IRS Reach Deal To Settle Transfer Pricing Dispute

    The Internal Revenue Service has reached a settlement with semiconductor manufacturer Microsemi to resolve the agency's transfer pricing adjustment regarding an intercompany purchase of semiconductor products, according to U.S. Tax Court filings.

Expert Analysis

  • Playing Soccer Makes Me A Better Lawyer

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    Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.

  • Adapting To Private Practice: From ATF Director To BigLaw

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    As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.

  • How Cos. In China Can Tailor Compliance Amid FCPA Shifts

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    The U.S. Department of Justice’s recently updated Foreign Corrupt Practices Act enforcement guidelines create a fluid business environment for companies operating in China that will require a customized compliance approach to navigate both countries’ corporate and legal systems, say attorneys at Dickinson Wright.

  • Playing Baseball Makes Me A Better Lawyer

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    Playing baseball in college, and now Wiffle ball in a local league, has taught me that teamwork, mental endurance and emotional intelligence are not only important to success in the sport, but also to success as a trial attorney, says Kevan Dorsey at Swift Currie.

  • 4 Former Justices Would Likely Frown On Litigation Funding

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    As courts increasingly confront cases involving hidden litigation finance contracts, the jurisprudence of four former U.S. Supreme Court justices establishes a constitutional framework that risks erosion by undisclosed financial interests, says Roland Eisenhuth at the American Property Casualty Insurance Association.

  • How Attys Can Use AI To Surface Narratives In E-Discovery

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    E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.

  • AbbVie Frees Taxpayers From M&A Capital Loss Limitations

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    The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.

  • ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'

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    The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.

  • Can Companies Add Tariffs Back To Earnings Calculations?

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    With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.

  • A Look At DOJ's Dropped Case Against Early Crypto Operator

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    The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.

  • 8 Ways Lawyers Can Protect The Rule Of Law In Their Work

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    Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.

  • Law School's Missed Lessons: Communicating With Clients

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    Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

  • Navigating Antitrust Risks When Responding To Tariffs

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    Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.

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