International

  • June 18, 2026

    Securitization Cos. Can Duck EU Interest Limits, Adviser Says

    Luxembourg correctly exempted securitization companies from the interest limitation rule under the European Union's anti-tax avoidance directive because they are comparable to financial undertakings that are explicitly exempted, an adviser to the European Court of Justice said Thursday.

  • June 18, 2026

    Medtronic Ruling Supports IRS In Amgen Case, Tax Court Told

    The IRS urged the U.S. Tax Court to back the agency's decision to allocate drugmaker Amgen's profits from the company's Puerto Rican subsidiary, arguing that the Eighth Circuit's ruling in Medtronic's case supports its pricing method.

  • June 18, 2026

    Indian Court Sides With US Gem Co. In Transfer Pricing Row

    A U.S. gem grading organization didn't have a taxable permanent establishment in India, and the government cannot tax royalties that the company refunded to its Indian counterpart, the Bombay High Court said in a judgment.

  • June 18, 2026

    Karaoke Chain Loses Bid For COVID VAT Refund

    A karaoke chain can't claim a value-added tax refund on bookings under a reduced rate for cultural shows and venues during the COVID-19 pandemic, a London tribunal has ruled, because the business's private rooms are exclusive.

  • June 17, 2026

    Tractor Supply Wrongly Shifted Income, SC Court Affirms

    South Carolina's tax agency did not exceed its authority when it imposed an alternative apportionment method on Tractor Supply Co. after asserting that the company and two affiliates had inappropriately shifted income to reduce state corporate tax liability, an appellate panel affirmed Wednesday.

  • June 17, 2026

    Tax Court Won't Rethink Basis Ruling Against Partnership

    A U.S. Tax Court judge said Wednesday that he won't reconsider his ruling that a company electing to be treated as a disregarded entity and attempting to pay for interest in a partnership with a promissory note from its parent can't claim a basis in the partnership.

  • June 17, 2026

    Varian Owes $7.2M After Deduction Limited, Tax Court Says

    Varian Medical Systems owes more than $7.2 million to the IRS as a result of the U.S. Tax Court limiting its deemed dividends deduction, the court said, accepting an agreement reached between the parties.

  • June 17, 2026

    Danish Financier Denied Tax Appeal For Missing Deadline

    A Danish financier and his company can't appeal a decision over a tax bill of over £866,000 ($1.2 million) despite his claim that they face a 200% tax rate, a London tribunal ruled, saying he had no good reason for missing a previous appeal deadline.

  • June 17, 2026

    Insurance Co.'s $1.35B Tax Fight Sent To Nova Scotia Court

    The Tax Court of Canada declined to hear Canadian revenue authorities' bid to include over CA$1.9 billion ($1.35 billion) worth of shares in a life insurance company's taxable capital, holding that jurisdiction belongs to a Nova Scotia court.

  • June 17, 2026

    VAT Break For Credit Management Has Limits, EU Court Says

    The European Union's value-added tax exemption for managing credit doesn't apply to management services provided by an entity that granted, transferred and continued managing the credit, an EU court said Wednesday in deciding questions for a Finnish bank's tax challenge.

  • June 17, 2026

    Hong Kong Tightens Bank Rules For Tax Info Exchanges

    Hong Kong lawmakers adopted a bill Wednesday to tighten requirements on financial institutions pursuant to the automatic exchange of information between tax authorities, building off suggestions made during a peer review of the jurisdiction's legal framework, the Inland Revenue Department said.

  • June 16, 2026

    2nd Circ. Won't Let Man Reverse Tax Plea Over Bad Advice

    The Second Circuit issued a summary order Tuesday affirming the conviction of a Connecticut man who pled guilty to tax crimes, disagreeing that allegedly misleading advice from trial attorneys about the immigration implications of his plea warranted his withdrawing it.

  • June 16, 2026

    Israeli Law Firm Has No Case Against GILTI Regs, Gov't Says

    An Israeli law firm cannot challenge IRS regulations implementing the 2017 tax law's global intangible low-taxed income regime largely because any connected compliance burden is borne by its U.S. shareholder, not the firm itself, the government told a D.C. federal court.

  • June 16, 2026

    Arizonan Owes $1.9M For Unreported Accounts, 9th Circ. Says

    An Arizona man is on the hook for $1.9 million in penalties for undisclosed foreign bank accounts, the Ninth Circuit ruled, rejecting his contention that a district court mishandled the process for facilitating the IRS' recalculation of the amount.  

  • June 16, 2026

    KC Defends Gardener Trust Deal In £2M Evasion Trial

    A senior barrister accused of cheating the public purse out of almost £2 million ($2.7 million) argued Tuesday that his former gardener perfectly understood that an agreement to be compensated for his services via a trust was not binding.

  • June 16, 2026

    Revamp Of EU Tax Rules Set To Change Reporting Hallmarks

    A shake-up of European Union rules on tax information sharing is set to change criteria that trigger reporting obligations, notably tweaking hallmarks of potentially aggressive tax arrangements, according to draft revisions seen Tuesday by Law360.

  • June 16, 2026

    EU Parliament Approves Trade Deal With US

    European Union lawmakers voted Tuesday to approve legislation implementing the bloc's safeguard-bolstered trade deal with the U.S. founded on a series of tariff cuts, moving one step closer to implementation that is expected before the end of the month.

  • June 16, 2026

    UK Seeks Input On New Transfer Pricing Reporting Rules

    The British government is seeking feedback from businesses and other stakeholders on draft rules for new reporting requirements for international controlled transactions, HM Revenue & Customs said Tuesday.

  • June 15, 2026

    HMRC Can Levy Exit Tax On Trust's £142M Gains, Court Rules

    Britain's tax authority can collect an exit tax charged on over £142 million ($190 million) in gains from a real estate company and on over £330,000 in assets from a family trust, provided that the tax is paid in a five-year installment plan, a London court ruled.

  • June 15, 2026

    Justices Won't Review Trump's First-Term China Tariff Hikes

    The U.S. Supreme Court refused Monday to review a case challenging tariffs that President Donald Trump installed and increased on Chinese goods during his first term.

  • June 15, 2026

    Dutch Gov't Rejects National Parcel Handling Fee

    The Dutch government rejected a request from lawmakers to introduce a national handling fee for parcels and will instead rely on measures at the European Union level.

  • June 15, 2026

    Disqualified Director Jailed For £3M Fraud, Money Laundering

    A company director has been sentenced to four years in prison for diverting more than £3 million ($4 million) through an insolvency fraud and money laundering scheme, the Insolvency Service said.

  • June 15, 2026

    KC Says He Was Entitled To Cut Tax Bill In £2M Evasion Case

    A senior barrister accused of cheating the public purse out of almost £2 million ($2.7 million) told a court on Monday that he was "morally entitled" to pursue a strategy to reduce his tax liability.

  • June 12, 2026

    Global Minimum Tax Was A Bad Bargain, Tax Pros Say

    The global minimum tax known as Pillar Two had the paradoxical goal of increasing countries' taxing power by having them cede some of their authority to set corporate rates — and ultimately would have hurt both wealthy and developing nations, tax specialists said at a conference Friday.

  • June 12, 2026

    Partnership Owes No Taxes On £13M Transfer, Court Says

    A U.K. appeals court ruled Friday against revenue authorities' bid to collect taxes on approximately £13 million ($17.4 million) that affiliated trusts transferred to a partnership after selling their shares in an industrial business.

Featured Stories

  • 4 Questions As Gov't Appeals Illegal Tariff Refund Suit

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    The government's appeal of an order requiring immediate refunds for tariffs that were deemed illegal by the U.S. Supreme Court earlier this year is the latest obstacle for importers forced to stall investments in new products and brace for a longer wait for their refunds in response.

  • 4 Key Questions Surrounding US Forced Labor Tariff Rates

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    New proposed U.S. tariffs meant to address goods tied to forced labor are likely to create new administrative burdens for importers, from new compliance hurdles domestically to the potential for retaliatory measures by trading partners on U.S. goods shipped abroad, attorneys told Law360.

  • Developers Stumped By Energy Credits' Foreign Debt Limits

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    Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.

Expert Analysis

  • Economic Questions To Ask Amid Tariff Refund Class Actions

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    The U.S. Supreme Court's recent holding that the International Emergency Economic Powers Act doesn't authorize the president to impose tariffs has sparked class actions, but determining whether a retailer received a windfall is complex, even if it passed tariff costs into consumer prices before receiving a refund, say economists at Ankura Consulting Group.

  • Cow Horse Makes Me A Better Lawyer

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    Moving an unwilling 800-pound cow while riding a horse at high speed is exhilarating, a little unhinged and, at least for me, a surprisingly effective training ground for litigation — both demand focus, preparation over rigid planning and the willingness to act despite fear, says Ashley Zitrin at Glenn Agre.

  • Checking For AI Errors Is Now A Two-Way Street

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    A handful of recent federal and state cases demonstrate the importance of checking for errors generated by artificial intelligence not only in your own court submissions, but also your opponent's, as well as when catching opposing counsel's AI mistakes could result in an award for attorney fees, says Tamara Barago at Hollingsworth.

  • 5 Things Associates Must Ask About Their Firm's Merger Plan

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    The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.

  • 2 'Rocket Dockets' And The Rules That Propel Them

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    The fastest civil trial courts in the country are currently in the Eastern District of Virginia and the Southern District of Florida, and their chief judges provide insights into the court rules that keep them ahead, says Robert Tata at Hunton.

  • Your Next Litigation Hold Should Cover AI Chat Logs

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    The Delaware Chancery Court’s recent decision in Fortis Advisors v. Krafton to treat a CEO’s artificial intelligence chats as substantive evidence is being read as a discovery warning to litigators, but there is a second duty-to-preserve lesson that is especially pertinent to in-house counsel, say attorneys at Faegre Drinker.

  • Studying Foreign Languages Makes Me A Better Lawyer

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    Studying Italian and Japanese has shown me that learning a new language can benefit a legal career in several ways, including by demonstrating the importance of approaching problems from a fresh perspective and the value of practicing patience with colleagues and clients, says Anna King at Genworth Financial.

  • Sold Inventory May Drive Tax Treatment Of Tariff Refunds

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    Companies determining the tax treatment of refunds expected following the U.S. Supreme Court's February decision invalidating tariffs imposed under the International Emergency Economic Powers Act should consider whether the tariff costs have already reduced their income considering the cost of goods sold, say attorneys at McDermott.

  • Adapting To AI-Driven Scrutiny Of Foreign Asset Disclosures

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    As the government expands AI-driven, cross-agency fraud detection, foreign asset disclosure should be viewed as part of a broader, data‑driven enforcement ecosystem that prioritizes consistency, documentation and proactive governance, says Logan Koehring at FBT Gibbons.

  • Tax Teams Get No Bright-Line Rule From AI Privilege Cases

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    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.

  • NY Times Word Puzzles Make Me A Better Lawyer

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    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.

  • Law School's Missed Lesson: Diagnose Before Arguing

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    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.

  • Judges On AI: How Courts Can Survive The Tech Revolution

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    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.