International
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September 21, 2026
IRS Again Delaying Dividend Anti-Abuse Regs
The IRS is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, the agency announced Monday.
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September 21, 2026
Varian, Gov't Appeal Foreign Dividend Decision To 9th Circ.
Varian Medical Systems Inc. is appealing a U.S. Tax Court decision that it owes more than $7.2 million to the Internal Revenue Service as a result of the court limiting its deemed dividends deduction, while the government is also appealing, according to filings in the Ninth Circuit.
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September 21, 2026
Canadian Man Owes Tax As Homebuilder, Court Says
A Canadian man owes about CA$540,000 ($385,200) in sales tax as the builder of a home sold for a profit despite claiming that his original motivation was to live in the home, the Tax Court of Canada found.
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September 21, 2026
IRS Asks 5th Circ. To Pause Microcaptive Rules Case
The IRS asked the Fifth Circuit to stay briefing in a global tax services provider's bid to revive its challenge to the agency's reporting rules for microcaptive insurance companies pending the resolution of a related case before the appeals court.
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September 21, 2026
Housing Lender Calls On UK To Ditch Building Safety Tax
The U.K. government should scrap its incoming building safety levy to reduce barriers to constructing new houses as part of its autumn budget, a property lender urged Monday.
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September 21, 2026
Funder Says $13M Albania Default Judgment Should Stand
Litigation funder Omni Bridgeway has urged a D.C. federal court to preserve a default judgment enforcing a roughly $13 million arbitral award against Albanian state entities, arguing they waited an unreasonable 18 months to appear despite receiving repeated notice of the case.
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September 21, 2026
New EU Customs Rules Kick In Amid E-Commerce Boom
A fresh set of European Union customs rules entered into force Monday to address new trade challenges, including the rapid expansion of e-commerce.
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September 18, 2026
Exxon Wins $456M Tax, Penalty Refund In Qatar Gas Case
Exxon is entitled to a $274 million tax refund for a deduction of interest expenses fully allocated to the company by its partnership with Qatar to extract natural gas, a Texas federal court said Friday in an order that indicated $182 million in penalties should be returned as well.
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September 18, 2026
House Bill Would Limit BEAT, Make Other Int'l Tax Changes
The U.S. would limit the scope of its base erosion and anti-abuse tax and modify several other international tax measures under a bill introduced by a Republican on the House Ways and Means Committee.
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September 18, 2026
Tax Tipster Fights For Whistleblower Award At DC Circ.
U.S. Tax Court wrongly upheld the IRS denying a whistleblower award for information about a taxpayer's transfer pricing despite the agency failing to follow its internal procedures, the individual told the D.C. appeals court.
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September 18, 2026
Taxation With Representation: Davis Polk, Latham, Sullivan
In this week's Taxation With Representation, a group backed by Michael Dell's family office and Sequence Holdings acquires a majority interest in The Baldwin Group, May Mobility merges with a blank check company, and Infineon Technologies sells its memory chip business to Winbond Electronics.
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September 18, 2026
Addison Lee Founder Loses £20M Appeal Over Tax Status
A businessman who founded British private car hire company Addison Lee can't avoid over £20.5 million ($27.4 million) in taxes after a London tribunal rejected his claim to nondomicile tax status over his family connections to Ireland.
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September 18, 2026
IRS Floats Tax Return Form With Question About Citizenship
The Internal Revenue Service released a draft version of the Form 1040 individual tax return that for the first time would include a question about the filer's citizenship status.
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September 18, 2026
Five Deny Tax Fraud Charges Over Payroll Outsourcing
Five individuals pleaded not guilty Friday at a London criminal court to tax fraud and money laundering charges linked to an HM Revenue and Customs investigation into a payroll outsourcing business.
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September 17, 2026
IRS Defends Regs In Meta's Fight Against $16B Tax Bill
The IRS urged the U.S. Tax Court to validate regulations that Facebook parent Meta is challenging in its fight against a nearly $16 billion tax bill, arguing that the social media giant is recycling arguments the Ninth Circuit already rejected.
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September 17, 2026
IRS Properly Nixed Whistleblower's Award Bid, Tax Court Says
The IRS didn't abuse its discretion in denying a whistleblower's bid for an award for information regarding alleged underpayments by a large multinational corporation, the U.S. Tax Court ruled Thursday, upholding the agency's determination that it had already identified the key issues for its investigation.
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September 17, 2026
Electricity Tax Rules Kept In Irish EU Reg Draft, Over Protests
The Irish government, currently leading the Council of the European Union, kept rules requiring tax rates on electricity to be no less favorable than those on natural gas in its revision of a draft EU regulation, despite some member states' objections, according to a document obtained Thursday by Law360.
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September 17, 2026
6 Convicted In €520M Mafia-Linked VAT Fraud Syndicate
A Milan court convicted six individuals of participating in a €520 million ($597 million) value-added tax fraud scheme involving electronics that was bankrolled by an Italian crime syndicate, the European Public Prosecutor's Office said Thursday.
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September 17, 2026
Canada Tax Court Limits Deductions Under Insurance Policy
Two brothers who run a Canadian agricultural machinery manufacturing business recently lost their dispute with federal revenue collectors after the Tax Court of Canada limited their attempt to claim millions in tax deductions through a complex life insurance arrangement.
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September 17, 2026
UK Film Tax Relief Rises Past £700M
The U.K. government paid out £702 million ($937 million) in a tax relief program for the film industry in the 2024-25 tax year, an increase of 39% from the previous year, according to official data published Thursday.
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September 17, 2026
HMRC Draft Rules Set 22% Charge On Cash In Stock ISAs
Britain's tax authority published draft rules Thursday for the 2027 cash limit for individual savings accounts, including a new flat-rate charge of 22% on interest earned on cash parked inside stocks and shares wrappers.
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September 17, 2026
Australian Tax Office Takes In $1.3B From Corp. Settlements
The Australian Taxation Office collected AU$1.3 billion ($925 million) in revenue from settlements with large corporations during the most recent tax year, representing 58% of the total disputed amount, the agency said Thursday.
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September 17, 2026
4 Arrested In €15.7M Phone Tax Fraud, EU Says
European authorities conducted searches, arrests and asset freezes as part of an investigation into a suspected cross-border value-added tax fraud involving online mobile phones sales, prosecutors said Thursday.
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September 17, 2026
UK Think Tank Urges New Taxing Powers For Growth
The Labour government should allow mayors to keep a greater share of corporate and income tax revenue to promote economic growth across the U.K., a think tank urged in a new report.
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September 16, 2026
House Clears Russia Sanctions Bill With New Tariff Powers
The U.S. House of Representatives approved legislation Wednesday that would enhance President Donald Trump's economic tools to pressure Russia and Iran, including new tariff authorities to impose duties on imports from countries found to economically support Russia, sending the bill to his desk.
Expert Analysis
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Tax Teams Get No Bright-Line Rule From AI Privilege Cases
Three recent appellate decisions that considered artificial intelligence in the context of attorney-client privilege protections illustrate that taxpayers and tax practitioners alike must consider the pertinent facts on a case-by-case basis, with particular attention to confidentiality, disclosure risk and system design, say attorneys at Morgan Lewis.
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NY Times Word Puzzles Make Me A Better Lawyer
Every morning I let The New York Times humble me with word games, which offer a chance to recalibrate my brain before the day's chaos arrives and remind me that a solution — whether to a puzzle or employment law issue — almost always exists once I find the right angle, says Amy Epstein Gluck at Pierson Ferdinand.
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Law School's Missed Lesson: Diagnose Before Arguing
Law school often skips over explicitly teaching students how to determine what kind of problem a case presents before they commit to a particular doctrinal path, which risks building arguments that are internally coherent but externally misaligned, says Melanie Oxhorn at Kobre & Kim.
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Judges On AI: How Courts Can Survive The Tech Revolution
Colorado Supreme Court Justice Maria Berkenkotter and Colorado Court of Appeals Judge Lino Lipinsky de Orlov discuss how artificial intelligence has already fundamentally altered the legal system and offer tips for courts navigating deepfakes, hallucinations and a gap in access to AI tools.
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3 AI Adoption Mistakes GCs Should Avoid
The pressure in-house legal teams face to quickly adopt artificial intelligence tools, combined with budget constraints and the need to evaluate a crowded market of options, sets the stage for implementation mistakes that are often difficult to undo, says former 23andMe general counsel Guy Chayoun.
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4 Emerging Approaches To AI Protective Order Language
Over the last year, at least five federal district courts have issued or analyzed specific protective order provisions restricting the use of generative artificial intelligence platforms with protected materials, establishing that proactive AI-specific provisions are now standard practice and demonstrating that no single model works for every case, says Joel Bush at Kilpatrick.
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Heppner Ruling Left AI Privilege Risk For Lawyers Unresolved
While a New York federal judge’s recent ruling in U.S. v. Heppner resolved a privilege question surrounding client-side artificial intelligence use, it did not address how to mitigate the risks that can arise when confidential information enters the operative context of an AI system used by an attorney, says Jianfei Chen at Quarles & Brady.
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Speed Jigsaw Puzzling Makes Me A Better Lawyer
My passion for speed puzzling — I can complete a 500-piece jigsaw puzzle in under 50 minutes — has sharpened my legal skills in more ways than one, with both disciplines requiring patience, precision and the ability to keep the bigger picture in mind while working through the details, says Tazia Statucki at Proskauer.
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Documenting Business Purpose After IRS' 10th Circ. Win
Following the Tenth Circuit’s recent Liberty Global v. U.S. decision, which held the economic substance doctrine does not require a threshold relevancy determination, taxpayers can prepare for potential audits by maintaining contemporaneous documentation and taking other steps that demonstrate the business purpose of transactions, say attorneys at Crowell & Moring.
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2 AI Snafus Show Why Attys Can't Outsource Judgment
The recent incident involving Sullivan & Cromwell where citations in a filed motion were fabricated by artificial intelligence, as well as a punitive ruling from the Sixth Circuit in U.S. v. Farris, demonstrate that the obligation to supervise AI has belonged and always will belong to lawyers, says John Powell at the Kentucky School Boards Association.
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Improving Well-Being In Law, 10 Years After Landmark Study
An important 2016 study revealed significant substance abuse and mental health issues among lawyers, and while the findings helped normalize the conversation around these topics, a decade later, structural change is still needed, says Denise Robinson at PLI.
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Hungary CPAC Funding Probe Could Implicate US Entities
A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political and financial dimensions that create multiple touchpoints for U.S. regulatory and enforcement interest, say attorneys at Ballard Spahr.
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Mitigating Multistate Risks As California Expands Tax Reach
Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain other steps to protect clients from the costs of losing a future audit, says attorney Delina Yasmeh.