International
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April 17, 2026
Tax Arbitrage Guidance Due This Year, OECD Official Says
The Organization for Economic Cooperation and Development hopes to publish guidance this year on tax arbitrage that could be relevant to the application of what's known as the Pillar Two side-by-side package, created to recognize the U.S. minimum tax system, an OECD official said Friday.
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April 17, 2026
Brexit Backer Owes Inheritance Tax On Donations, Court Says
A former hedge fund manager who donated about £750,000 ($1 million) to political groups that mostly advocated for Brexit isn't exempt from about £100,000 of inheritance tax on his donations, the First-tier Tribunal said in a judgment.
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April 17, 2026
Taxation With Representation: Skadden, Stikeman Elliott
In this week's Taxation With Representation, Amazon.com Inc. buys satellite communications company Globalstar Inc., waste management company GFL Environmental Inc. acquires Secure Waste Infrastructure Corp., and Standard Life PLC buys the British subsidiary of Dutch insurer Aegon.
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April 17, 2026
Furniture Cos.' $19M Captive Insurance Scam Suit Resumed
A Maryland federal court has resumed a lawsuit accusing a D.C. corporate tax attorney and his former law firm of a $19 million captive insurance scam following notification that the bankruptcy proceedings of the attorney and the firm have concluded.
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April 17, 2026
Taxing Digital Economy Gaining More Traction, OECD says
An official from the Organization for Economic Cooperation and Development said Friday that the Paris-based group is engaging in constructive dialogue on the taxation of the digital economy as interest in the subject grows.
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April 16, 2026
Senate Bill Seeks To End Carried Interest Tax Break
Fund managers would face annual taxation of carried interest based on imputed compensation, instead of primarily enjoying long-term capital gains rates, under a bill introduced Thursday by Senate Finance Committee ranking member Ron Wyden, the latest in a decades-long drive to end the tax break.
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April 16, 2026
UK Travel Co. Can Challenge VAT Credit Adjustment
A travel agency can proceed with challenging HM Revenue & Customs' trimming of its value-added tax credit by about £187,000 ($253,000) after a court spiked the U.K. tax authority's bid for an early end to the case.
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April 16, 2026
UK Firms Wary Of Loan-Out Contracts, Paramount VP Says
Companies across various industries are becoming more hesitant to employ people via loan-out firms because of concerns about their own tax liabilities, a Paramount Global vice president said Thursday.
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April 16, 2026
Texas Judge Vacates IRS' Steep Microcaptive Reporting Rule
A Texas federal judge vacated a tax code regulation designating microcaptive insurance transactions as listed transactions subject to deep scrutiny and hefty penalties, saying the Internal Revenue Service didn't prove that they are mostly for tax avoidance and not really for insurance.
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April 16, 2026
Defunct Canada Law Firm Can't Get Bad Debt Tax Deduction
A shuttered Canadian law firm can't get a tax break on unpaid client bills, the Tax Court of Canada ruled, holding that the firm didn't make a sufficient effort to chase down payments before claiming a bad debt deduction.
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April 16, 2026
OECD To Address Double-Tax Policy Quirk, Official Says
The Organization for Economic Cooperation and Development is working to iron out a policy quirk that can result in double taxation when it is unclear whether restrictions on interest deductions fall under domestic tax rules or international treaty frameworks, an OECD official said Thursday.
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April 16, 2026
Canadian Bank Defeats Country-By-Country Tax Proposal
Shareholders of the Canadian Imperial Bank of Commerce voted against a proposal to require the bank to disclose public country-by-country reports of tax information Thursday, with only about 10% of shareholders voting in favor.
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April 15, 2026
Centrica Loses £5.3M Tax Dispute Over North Sea Gas Field
Centrica's activities in a North Sea natural gas field amount to oil extraction, and therefore the company is liable for corporate tax bills totaling £5.3 million ($7.2 million) under the rules governing energy taxation, according to a London tribunal.
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April 15, 2026
Cross-Border Services Taxes Are 'Quasi-Tariffs,' Report Says
The U.S. arguably has a stronger interest in challenging digital services taxes and other "quasi-tariffs" than in pursuing tariffs on physical goods, according a report Wednesday from the Tax Foundation, which contended that these overseas taxes disproportionately harm large services exporters.
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April 15, 2026
UK Tribunal Says Director Owed Tax On Written-Off Loan
The former director of a defunct U.K. company is on the hook for taxes and penalties after he failed to report a canceled debt to tax authorities, a U.K. court ruled Wednesday.
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April 15, 2026
Eaton Says Tax Court Can't Disregard Transfer Of $14B Asset
The U.S. Tax Court can't disregard Eaton's transfer of a $14 billion asset overseas because the IRS itself didn't challenge the transaction's validity, the company argued Wednesday in defending the interest rates and guarantee fees paid to its Irish parent in 2012 and 2013.
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April 15, 2026
Builders Brace To Fight Tax Fraud 'Should Have Known' Test
Britain's tax agency has begun to wield strengthened enforcement powers to combat tax fraud in the construction industry after reforms that lawyers warn could trigger disputes as businesses challenge whether they meet the regime's contentious "should have known" test.
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April 15, 2026
Orsted Loses Top UK Court Case Over Wind Farm Tax Break
A Danish wind farm company cannot claim tax relief on pre-development costs for building wind farms, Britain's top court held Wednesday, ruling that the costs are not sufficiently connected to the provision of plants and machinery.
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April 14, 2026
Siemens Says It Met Conditions For $671M Deduction
Siemens Medical Solutions is entitled to a $670.6 million foreign-dividend tax deduction because it met the three prerequisites set forth in the statute governing the deduction, the company told the U.S. Tax Court.
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April 14, 2026
Canada To Suspend Fuel Taxes Amid War In Iran
Canada will temporarily suspend excise taxes on fuel, a CA$2.4 billion ($1.7 billion) expenditure aimed at combating price spikes linked to the U.S. and Israel's war in Iran, Prime Minister Mark Carney said Tuesday in his first action after winning a governing majority.
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April 14, 2026
IRS Audited 3% Of Rich Taxpayers Pegged As Flouting FATCA
The IRS audited just 3% of taxpayers with $6.2 trillion offshore who were identified as noncompliant with the Foreign Account Tax Compliance Act and assessed no penalties to the vast majority of "egregious nonfilers," the Treasury Inspector General for Tax Administration said in a report.
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April 14, 2026
Customs Casts Doubt On Automating Certain Tariff Refunds
U.S. Customs and Border Protection's automated tariff refund system is nearly complete, but thousands of imports may require a more cumbersome manual process that could undermine the agency's other priorities, an official told the U.S. Court of International Trade on Tuesday.
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April 14, 2026
Canada Appeals Court Denies Costs To Gov't In Tax Disputes
Canada's government will not receive enhanced legal costs for tax disputes with two companies where it largely prevailed because it failed to demonstrate that related cases held in abeyance justified the extra award, according to the Federal Court of Appeal.
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April 14, 2026
2nd Circ. Urged To Rethink IRS Win In Foreign Reporting Case
A New York business owner asked the Second Circuit to rethink a panel's decision that held the IRS could automatically assess and administratively collect certain foreign information reporting penalties, arguing that the ruling deepens a nationwide conflict about the agency's assessment authority.
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April 14, 2026
Fire Alarm Biz Boss Banned Over £327K Tax Dodging
The owner of two fire alarm companies has been banned from running businesses for six years after dodging more than £327,000 ($444,000) in income tax and value-added tax owed to the U.K.'s tax authority, the Insolvency Service said Tuesday.
Expert Analysis
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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Calif.'s Civility Push Shows Why Professionalism Is Vital
The California Bar’s campaign against discourteous behavior by attorneys, including a newly required annual civility oath, reflects a growing concern among states that professionalism in law needs shoring up — and recognizes that maintaining composure even when stressed is key to both succeeding professionally and maintaining faith in the legal system, says Lucy Wang at Hinshaw.
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US-Ukraine Reconstruction Fund Tax Exemptions Uncertain
Tax provisions in the bilateral agreement to establish the U.S.-Ukraine Reconstruction Investment Fund, which recently announced it is accepting applications, are so broad and imprecise as to leave uncertainty regarding whether and when tax exemptions will apply to investors' income, say attorneys at Avellum and Debevoise.
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Trivia Competition Makes Me A Better Lawyer
Playing trivia taught me to quickly absorb information and recognize when I've learned what I'm expected to know, training me in the crucial skills needed to be a good attorney, and reminding me to be gracious in defeat, says Jonah Knobler at Patterson Belknap.
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Judges On AI: Practical Use Cases In Chambers
U.S. Magistrate Judge Allison Goddard in the Southern District of California discusses how she uses generative artificial intelligence tools in chambers to make work more efficient and effective — from editing jury instructions for clarity to summarizing key documents.
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Malpractice Claim Assignability Continues To Divide Courts
Recent decisions from courts across the country demonstrate how different jurisdictions balance competing policy interests in determining whether legal malpractice claims can be assigned, providing a framework to identify when and how to challenge any attempted assignment, says Christopher Blazejewski at Sherin & Lodgen.
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NYC Bar Opinion Warns Attys On Use Of AI Recording Tools
Attorneys who use artificial intelligence tools to record, transcribe and summarize conversations with clients should heed the New York City Bar Association’s recent opinion addressing the legal and ethical risks posed by such tools, and follow several best practices to avoid violating the Rules of Professional Conduct, say attorneys at Smith Gambrell.