International

  • March 03, 2026

    Fed. Circ. Wrestles With Treaty Language In Tax Credit Fights

    A Federal Circuit panel grappled Tuesday with how to interpret a phrase in the U.S. government's tax treaties with Canada and France that allows foreign tax credits subject to limitations in the Internal Revenue Code as it weighed two refund disputes.

  • March 03, 2026

    DC Circ. Urged To Aid Discovery In ICE-IRS Data-Sharing Case

    A taxpayer group challenging the legality of a deal allowing the Internal Revenue Service to share taxpayer location information with immigration authorities asked the D.C. Circuit to remand part of the case to investigate the IRS' admission that it improperly shared addresses under the agreement.

  • March 03, 2026

    UK Tribunal Blocks Firm From Reviving Wage Subsidy Claim

    A flooring company cannot challenge a lower court's ruling that HM Revenue & Customs correctly used a lower salary figure than provided to determine payments under a wage subsidy scheme during the COVID-19 pandemic, the Upper Tribunal said in a decision released Tuesday.

  • March 03, 2026

    Gov't Goes After $19M In Biofuel Tax Credit Fraud Case

    A businessman who owes more than $19 million to a company subject to forfeiture over its involvement in a $511 million biofuel tax credit fraud must hand over the money to the federal government now that a catfishing scheme targeting him is resolved, the government told a Utah federal court.

  • March 03, 2026

    Reeves Says UK Will Stick With Higher Tax Take Strategy

    Chancellor of the Exchequer Rachel Reeves said Tuesday that the U.K. government will keep its plans to meet its fiscal rules by increasing its tax take despite calls for tax cuts from businesses and concerns over financial stability.

  • March 03, 2026

    EU Energy Groups Seek Extension Of VAT Fraud Fighting Tool

    Energy associations urged European Union lawmakers Tuesday to extend a tool used to fight value-added tax fraud that is set to expire in December, saying an extension will ensure the proper functioning of carbon emissions markets and energy certificate trading.

  • March 02, 2026

    Fed. Circ. Quickly Releases Mandate In Trump Tariff Case

    Businesses and states that successfully challenged President Donald Trump's global tariff regime can proceed with their efforts to seek refunds, as the Federal Circuit expedited the release of its mandate in the case to the U.S. Court of International Trade on Monday.

  • March 02, 2026

    Disregarded Entity Can't Claim Basis In Partnership

    A company that elected to be treated as a disregarded entity — a branch of its parent — and attempted to pay for interest in a partnership with a promissory note from the parent can't claim a basis in the partnership for 2009, the U.S. Tax Court held Monday.

  • March 02, 2026

    FedEx Customers Seek Refunds For Passed-On Tariff Costs

    A proposed class action in Florida federal court looks to make sure FedEx refunds customers for the costs of tariffs the shipping giant passed on to them as the company looks to recoup its payments made under President Donald Trump's illegal tariff regime.

  • March 02, 2026

    Int'l Tax In February: Check On US Tariffs Prompts Reactions

    Over the past month, new U.S. Internal Revenue Service rules on clean fuel and energy tax credits have brought certainty for some taxpayers, even as the end of tariffs imposed under the U.S. International Emergency Economic Powers Act has created new uncertainty around recent trade deals with India and the European Union. Here, Law360 looks at the biggest international tax developments in February.

  • March 02, 2026

    China Seeking To Stop Illegal Tax Breaks By Local Gov'ts

    China has been clamping down on illegal efforts by local governments to attract investment by providing tax breaks to taxpayers who reside or operate outside their jurisdictions, the country's State Taxation Administration said Monday.

  • March 02, 2026

    HMRC Bags Extra £16B From Big Businesses, Audit Says

    HM Revenue & Customs collected almost £16 billion ($21.3 billion) in extra tax revenue from the biggest businesses in fiscal year 2024-25 after it took a stricter approach to compliance, the National Audit Office found.

  • March 02, 2026

    Guernsey Weighs Wider Access To Beneficial Ownership Info

    Guernsey is considering allowing people who can demonstrate a "legitimate interest," such as journalists, nongovernmental organizations and due diligence service providers, to access beneficial ownership information about companies in its jurisdiction, according to the government.

  • March 02, 2026

    Australian Tax Debt Relief Flagged As Inconsistent

    The Australian Taxation Office has been inconsistent about when it reduces interest charges on tax debts for individuals and small businesses, leading to "confusion and unfair outcomes," according to a report Monday by the country's tax watchdog.

  • March 02, 2026

    Spanish Official To Lead OECD Tax Transparency Forum

    A Spanish tax official has been appointed to lead the secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, the Organization for Economic Cooperation and Development said.

  • March 02, 2026

    Customs, VAT Fraud Costing €45B, EU Prosecutors Say

    Cross-border customs and value-added tax fraud are reshaping the criminal landscape in the European Union, with such schemes generating an estimated €45 billion ($52.7 billion) in damage, according to a report published Monday by an independent prosecuting body.

  • February 27, 2026

    Older UK Homeowners Tap £6.2B Home Equity To Cut Tax Bills

    A growing number of people in the U.K. over age 66 are turning to equity release to reduce their inheritance tax liability, with £6.2 billion ($8.4 billion) in mortgage releases in 2024-25, according to financial data revealed Saturday.

  • February 28, 2026

    2nd Circuit Says IRS Can Apply Foreign Biz Reporting Penalty

    The Internal Revenue Service may use administrative assessment to collect penalties from a taxpayer for failing to report control of a foreign business from 2005 to 2009, the Second Circuit held Friday, vacating a U.S. Tax Court ruling.

  • February 27, 2026

    Trump's Trade Deals Face Tricky Path After Tariff Ruling

    While President Donald Trump has said the trade agreements struck in response to tariffs that have now been invalidated by the U.S. Supreme Court will be kept, navigating the terms of those deals in the aftermath is already proving complicated.

  • February 27, 2026

    Denmark's Top Party Plans Wealth Tax Ahead Of Elections

    Denmark's top party has proposed a 0.5% wealth tax as a pillar of its platform for early elections called by a prime minister seeking to build on public support for her efforts to prevent the U.S. from taking over Greenland.

  • February 27, 2026

    Taxation With Representation: Linklaters, Wilson Sonsini

    In this week's Taxation With Representation, French electric utility Engie acquires UK Power Networks, Gilead Sciences Inc. buys clinical-stage biotechnology company Arcellx Inc., and The Brink's Co. acquires NCR Atleos in a deal that unites two major companies in the ATM business.

  • February 27, 2026

    UK Christian Schools Pledge Top Court Appeal After VAT Loss

    A group of Christian families and schools said they will take their appeal against the 20% value-added tax charged on their private school fees to the U.K. Supreme Court after an appeals court dismissed their case Friday.

  • February 26, 2026

    IRS Broke Law 42K Times By Giving Info To ICE, Judge Says

    The federal judge who stopped the Internal Revenue Service from sharing taxpayer addresses with immigration authorities said Thursday that a recent admission by the agency showed that it broke the law more than 42,000 times last summer when it disclosed addresses by relying on a computerized matching system.

  • February 26, 2026

    Penalties Apply In 'Missing Witness' Case, Tax Court Says

    The U.S. Tax Court won't reconsider its decision that a couple who had argued they were misled by their accountant are liable for penalties over failing to file and failing to pay estimated tax in a case where they neglected to call the accountant as a witness.

  • February 26, 2026

    Biz Owner Gets £2M Tax Evasion Penalty Tossed As Unfair

    A company owner isn't liable for a nearly £2 million ($2.7 million) civil tax evasion penalty because HM Revenue & Customs didn't raise its claims of dishonesty by the owner in a prior proceeding it relied on later, a London court said Thursday.

Expert Analysis

  • 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.

  • Key Points From HMRC's Tax Reform Proposals

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    Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • What To Note As UK Adopts OECD Crypto Disclosure Rules

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    With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

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