International

  • July 18, 2025

    Western Union Says IRS Used Flawed Rule To Hike Income

    The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.

  • July 18, 2025

    Taxation With Representation: Wachtell, Slaughter And May

    In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.

  • July 18, 2025

    European Tax Policy To Watch In 2nd Half Of 2025

    The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months.

  • July 18, 2025

    EU To Make Foreign Traders Liable For VAT On Imports

    Foreign companies, rather than consumers, will become liable for value-added tax on imports to the European Union beginning July 2028 under a directive adopted Friday by the bloc's council of member states, according to a news release.

  • July 18, 2025

    Oman, Trinidad And Tobago 'Largely Compliant,' OECD Says

    Reviews of the implementation of tax transparency measures in Oman and in Trinidad and Tobago found both nations "largely compliant" with Organization for Economic Cooperation and Development standards, the OECD said Friday.

  • July 17, 2025

    Canada Mulling Changes To Ability To Rewrite Transactions

    Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.

  • July 17, 2025

    US Negotiating Global Min. Tax Carveout Accord, Official Says

    The U.S. hasn't yet secured an agreement with other countries to exempt its companies from the international parts of the 15% global minimum tax despite reaching an "understanding" with the Group of 7 nations, but wider negotiations have begun, a U.S. Treasury Department official said Thursday.

  • July 17, 2025

    EU Warns Dutch Over Tax Breaks Favoring Foreign Investment

    The Netherlands may have to face the Court of Justice of the European Union if it does not amend a tax measure that provides incentives for investment in foreign companies over domestic businesses, the European Commission announced Thursday.

  • July 17, 2025

    EU Lawmakers Push For Tax Data Hub To Combat Evasion

    Members of the European Parliament approved proposals for tax changes across the European Union, including a tax data hub to streamline compliance across the bloc and help combat tax avoidance and evasion.

  • July 17, 2025

    US Challenge To Belgian Minimum Tax Rules Heads To ECJ

    A Belgian court said Thursday it has asked the European Union's highest court to weigh in on a U.S. industry group's challenge to the country's global minimum tax rules.

  • July 17, 2025

    Tax Info Swaps Have Generated €135B Since 2009, OECD Says

    The international push for widespread adoption of tax transparency measures such as exchanges of information has led to €135 billion ($156 billion) in added revenue — including taxes, penalties and interest — since 2009, the Organization for Economic Cooperation and Development said Thursday.

  • July 17, 2025

    Australia Seeks Comments On Pillar 2 Guidance

    The Australian Taxation Office is looking for public comments on a pair of draft guidelines related to the country's adoption of the Organization for Economic Cooperation and Development's Pillar Two global corporate minimum tax on large multinational entities.

  • July 16, 2025

    OECD Mulling Tweaks To Arm's-Length Range Guidance

    The Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday.

  • July 16, 2025

    Tax Losses Back Retired Prof's FBAR Penalties, US Says

    A retired professor's admission in U.S. Tax Court that his failure to report his foreign bank accounts caused tax losses shows that a California federal court should affirm tax penalties against him of more than $400,000, the U.S. government said.

  • July 16, 2025

    EU Proposes New Tax On Large Cos. In Budget For 2028-2034

    The European Commission raised the idea Wednesday of a new tax on all companies that operate in the European Union with more than €100 million ($116 million) in annual revenue to augment its €2 trillion budget proposal for 2028 through 2034.

  • July 16, 2025

    German Chancellor Calls For EU Halt To Global Minimum Tax

    German Chancellor Friedrich Merz has called for the suspension of the European Union's rollout of the global corporate minimum tax, a German newspaper reported Wednesday.

  • July 16, 2025

    USTR To Probe Brazil's Trade Practices For Possible Tariffs

    The Office of the U.S. Trade Representative announced Tuesday evening it will launch an investigation into Brazil's trade practices to determine whether tariff actions could be necessary after a request by President Donald Trump and prior tariff threats.

  • July 16, 2025

    India Uses AI In Fraudulent Tax Crackdown, Recovers $122M

    A sweeping enforcement operation by the Indian tax authority used artificial intelligence and third-party financial data to uncover widespread abuse of tax deductions and exemptions, so far recovering 1,045 crore rupees ($122 million), the government said.

  • July 16, 2025

    Freight Co. Loses Interim Bid To Lift HMRC Export Controls

    A warehouse operator and drinks merchant have lost a bid for interim relief against U.K. tax authority export controls imposed over tax fraud concerns, with a London court ruling they had an "uphill task" to prove the measures were unreasonable.

  • July 15, 2025

    Trump Says US Has Struck Trade Deal With Indonesia

    President Donald Trump announced Tuesday that the U.S. has reached a trade deal with Indonesia that includes a 19% tariff on all goods exported by the Southeast Asian country to the U.S., while American goods exported there will be free of tariffs. 

  • July 15, 2025

    Tax Return Preparer Cops To Role In $25M Fraud Scheme

    A tax return preparer pled guilty in a California federal court for his role in a fraud scheme that involved submitting fake federal income tax returns to claim $25 million in refunds.

  • July 15, 2025

    UK Tech Co. Can't Deduct Tax Linked To VAT Fraud

    HM Revenue & Customs was correct to deny a technology supplier's £1.3 million ($1.7 million) tax refund bid, a U.K. court ruled, holding that the company should have known that the underlying transactions were tied to value-added tax fraud.

  • July 15, 2025

    Insurers Keen On UK Captive Regime But Fear 'Gold-Plating'

    The government has proposed new rules that it hopes will transform the U.K. into a global hub for captive insurance — but experts say that with formal regulation still to come they fear that "the devil will be in the detail."

  • July 15, 2025

    Ireland Spent €1.4B On R&D Tax Credits In 2023

    Ireland's biggest tax expenditure by far is its research and development tax credit, with the country forgoing around €1.4 billion ($1.6 billion) in revenue in 2023 in connection to the credit, the Irish Department of Finance said Tuesday.

  • July 15, 2025

    PwC Settles Property Biz's £9M Tax Negligence Case

    PwC has settled claims that it should pay £8.9 million ($12 million) for causing a property group to be penalized by the U.K. tax authority after the Big Four accountancy firm allegedly miscalculated its tax liabilities and incorrectly priced its properties.

Expert Analysis

  • Reading The Tea Leaves On Mexico, Canada And China Tariffs

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    It's still unclear whether the delay in the imposition of U.S. tariffs on Canadian and Mexican imports will result in negotiated resolutions or a full-on trade war, but the outcome may hinge on continuing negotiations and the Trump administration's possible plans for tariff revenues, say attorneys at Eversheds Sutherland.

  • How Design Thinking Can Help Lawyers Find Purpose In Work

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    Lawyers everywhere are feeling overwhelmed amid mass government layoffs, increasing political instability and a justice system stretched to its limits — but a design-thinking framework can help attorneys navigate this uncertainty and find meaning in their work, say law professors at the University of Michigan.

  • The Pros And Cons Of A 2nd Trump Term For UK Tech Sector

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    While U.S. President Donald Trump’s protectionist stance on trade could disrupt global supply chains on which many U.K. tech firms are reliant, anticipated deregulation could provide fertile ground for investment and growth, and the U.K. tech sector is bracing for a mix of opportunities, say lawyers at Shoosmiths.

  • Corp. Transparency Act's Future Under Treasury's Bessent

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    The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.

  • A Look At A Possible Corporate Transparency Act Exemption

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    Attorneys at Kirkland offer a deep dive into the application of the Corporate Transparency Act's reporting requirements specifically to U.S.-domiciled co-issuers in typical collateralized loan obligation transactions, and consider whether such issuers may be able to assert an exemption from the CTA's reporting requirements.

  • Inconsistent Injury-In-Fact Rules Hinder Federal Practice

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    A recent Third Circuit decision, contradicting a previous ruling about whether consumers of contaminated products have suffered an injury in fact, illustrates the deep confusion this U.S. Supreme Court standard creates among federal judges and practitioners, who deserve a simpler method of determining which cases have federal standing, says Eric Dwoskin at Dwoskin Wasdin.

  • In-House Counsel Pointers For Preserving Atty-Client Privilege

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    Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.

  • Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example

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    Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.

  • Accountant-Owned Law Firms Could Blur Ethical Lines

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    KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.

  • AI Will Soon Transform The E-Discovery Industrial Complex

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    Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.

  • Unpacking The Legal Foundation Of Trump's New Trade War

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    President Donald Trump's recent executive orders and proclamations regarding emergencies at the U.S. border are based on statutory powers enabling a president to address extraordinary external threats — and could be used to fend off legal challenges to the tariffs levied on Mexican and Canadian goods, says Chris Zona at Mandelbaum Barrett.

  • When Innovation Overwhelms The Rule Of Law

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    In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.

  • Imagine The Possibilities Of Openly Autistic Lawyering

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    Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.

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