International

IRS' Proposed Voluntary Disclosure Rule Could Be Dissuasive

Natalie Olivo
Senior Tax Correspondent

The IRS has proposed relaxing the 75% civil fraud penalty for participants in its voluntary disclosure program, but a corresponding 90-day deadline for complying with all payment and filing requirements could discourage some taxpayers from coming forward.

4 Key Questions On Tariff Investigations

Dylan Moroses

The U.S. announced a bevy of new trade investigations this month to underpin a tariff regime intended to replace duties struck down by the U.S. Supreme Court, but questions remain about the fate of deals struck with trading partners and whether importers will face higher tariffs. Here, Law360 examines four questions on the implications of those investigations.

Middle East Residents Fleeing War Face Tax Bills In UK

Josh White

British citizens who reside in the United Arab Emirates and other Persian Gulf states returning home because of the war in Iran may face tax bills from HM Revenue & Customs on overseas deals, as Britain's tax authority appears unlikely to make concessions for them.

What A Court Doc Audit Reveals About Erroneous Filings

My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.

Getting The Most Out Of Learning And Development Programs

Excerpt from Practical Guidance

Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.

AI Presents A Make-Or-Break Moment For Outside Counsel

The rapid adoption of artificial intelligence by corporate legal departments is forcing a long-overdue reset of the relationship between inside and outside counsel, and introducing a significant opportunity to shed frustrating inefficiencies and strengthen collaboration for firms willing to embrace the shift, says Intel Chief Legal Officer April Miller Boise.

8 Tariff Refund Questions For Restructuring Professionals

For restructuring and turnaround professionals, seeking refunds following the U.S. Supreme Court's recent decision invalidating tariffs imposed under the International Emergency Economic Powers Act raises several questions about how to capture legitimate recoveries while protecting an enterprise from the consequences of its own history, says Jonny Frank and Laura Greenman at StoneTurn, and Andrew Popescu at Province.

5 Tips For Navigating Your Firm's All-Attorney Summit

Excerpt from Practical Guidance

Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.

The Benefits Of Choosing A Niche Practice In The AI Age

As artificial intelligence becomes increasingly accessible, lawyers with a niche practice may stand out as clients seek specialized judgment that automation cannot replicate, but it is important to choose a niche that is durable, engaging and a good personal fit, says Daniel Borneman at Lowenstein Sandler.

Tax Court Ruling Signals Cross-Border Loan Scrutiny

The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.

How Banks Can Apply FinCEN Beneficial Ownership Relief

A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.

Aligning Microsoft Tools With NYC Bar AI Recording Guidance

The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.

5 Different AI Systems Raise Distinct Privilege Issues

A New York federal court’s recent U.S. v. Heppner decision, holding that a defendant’s use of Claude was not privileged, only addressed one narrow artificial intelligence system, but lawyers must recognize that the spectrum of AI tools raises different confidentiality and privilege questions, says Heidi Nadel at HP.

AI-Assisted Arbitration Needs Safeguards To Ensure Fairness

As tribunals and arbitral institutions increasingly use artificial intelligence tools in their decision-making processes, ​​​​​​​clear disclosure standards and procedural safeguards are necessary to ensure that efficiency gains do not erode the fairness principles on which arbitration depends, says Alexander Lima at Wesco International.

AI-Generated Doc Ruling Guides Attys On Privilege Risks

A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.

The Law Firm Merger Diaries: Leadership Strategy After Day 1

For law firm leaders, ensuring a newly combined law firm lives up to its promise, both in its first days of operation and well after, includes tough decisions, clear and specific communication, and cheerleading, says Peter Michaud at Ballard Spahr.