International

  • June 02, 2025

    Halliburton Wants IRS To Release Docs In $35M Tax Dispute

    The Internal Revenue Service should be ordered to comply with Halliburton's discovery requests in a dispute over a $35 million deduction for payments the company said it made to a foreign government to protect its employees from harassment, the company told a Texas federal court.

  • June 02, 2025

    GOP Budget Adds Punitive Twist To Talks On Digital Taxes

    The House-passed budget's punitive tax hikes on companies and people from countries with digital services taxes is poised to complicate trade negotiations aimed at removing DSTs and to weaken foreign investment in the U.S., fiscal experts told Law360.

  • June 02, 2025

    Remote Workers Take German Tax Case To EU's Top Court

    The European Court of Justice said Monday it will hear the case of two taxpayers against a German regional tax authority over whether Swiss residents working remotely are taxable in Germany.

  • June 02, 2025

    CJEU Set To Hear SocGen's Case In Swedish Tax Dispute

    The Court of Justice of the European Union said Monday that it will hear the case of French banking giant Société Générale SA against the Swedish tax authority over the taxation of nonresident companies under the European treaty.

  • June 02, 2025

    OECD Releases Consolidated Text Of Data-Swap Guidance

    The Organization for Economic Cooperation and Development published consolidated text of a global reporting standard Monday to help tax administrations exchange financial information about individuals who may be trying to hide money from their tax authorities at home.

  • June 02, 2025

    IRS To Hold Hearing On Sourcing Cloud Transaction Income

    The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.

  • May 30, 2025

    US-China Trade Talks Could Resume After Stall Over Minerals

    Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.

  • May 30, 2025

    Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight

    An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.

  • May 30, 2025

    HMRC Correctly Handled Land Tax Dodge, UK Court Says

    HM Revenue & Customs followed the correct procedures to collect taxes on six individuals who attempted to dodge the U.K.'s land tax by transacting with a special purpose vehicle in Guernsey, the Upper Tribunal ruled.

  • May 30, 2025

    Isle Of Man Agrees To Work With UK Against Tax Avoidance

    Isle of Man authorities reached an agreement with the U.K. government to work together in a crackdown on promoters of tax avoidance schemes, according to a joint statement.

  • May 30, 2025

    UK Midsize Biz Owners Wary Of Risk Exposure, Report Says

    Owners and operators of midsize U.K. businesses are just as wary of risk exposure in personal taxes as they are in business taxes except under certain circumstances, according to a report commissioned by HM Revenue & Customs.

  • May 30, 2025

    Taxation With Representation: Kirkland, Cravath, Latham

    In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.

  • May 29, 2025

    DC Court Blocks Trump's Tariffs As Overreach Of Power

    The International Emergency Economic Powers Act does not empower the president to impose tariffs, the D.C. federal district court said Thursday, ruling that President Donald Trump's global levies are unlawful and barring his administration from enforcing them on two toymakers who challenged the policies.

  • May 29, 2025

    Fed. Circ. Revives Trump Tariffs As It Weighs Appeal

    The Federal Circuit temporarily reinstated President Donald Trump's global tariffs Thursday, a day after the U.S. Court of International Trade held that an emergency law did not give the president "unbounded authority" to impose the measures.

  • May 29, 2025

    Australia Outlines Compliance For Thin Capitalization Test

    The Australian Taxation Office is looking for feedback on draft compliance guidance for corporations looking to use one of its new thin capitalization tests as they relate to cross-border financing arrangements, it said Thursday.

  • May 29, 2025

    £2.4B Employment Tax Credit Has Limited Value, Report Says

    A U.K. employment tax credit worth around £2.4 billion ($3.2 billion) a year in payroll tax relief for businesses has limited value, according to a report commissioned by HM Revenue & Customs, with the smallest businesses reaping the most benefit.

  • May 29, 2025

    Biz Group Calls On EU To Resolve Pillar 2 Dispute With US

    The European Union should work quickly to resolve problems with the Pillar Two global minimum corporate tax and its interaction with the U.S. tax system, the American Chamber of Commerce for the EU said.

  • May 29, 2025

    IRS Annual Gross Collections Top $5 Trillion For First Time

    The Internal Revenue Service collected $5.1 trillion in gross revenue in fiscal year 2024, a 9% increase over last year's $4.7 trillion total, marking the first time the tax haul has been above $5 trillion, the agency said Thursday.

  • May 29, 2025

    US Tariffs Spark Profit Warnings For UK Pension Sponsors

    British businesses might seek to tap into pension surpluses because of ongoing financial losses caused by U.S. tariffs, a professional services firm has warned.

  • May 28, 2025

    International Trade Court Strikes Down Trump's Tariffs

    The International Emergency Economic Powers Act does not give the president the "unbounded authority" to impose tariffs on goods from nearly every country in the world, the U.S. Court of International Trade ruled Wednesday, handing a win to small businesses and states challenging some of President Donald Trump's steep tariffs.

  • May 28, 2025

    Fintech Group Warns Remittance Tax Will Hurt Consumers

    The American Fintech Council sent a letter to members of Congress asking them to reconsider a proposed tax on remittances that is a part of the $3.8 trillion bill to extend and make permanent the Republican Party's 2017 tax overhaul law, also known as The One Big Beautiful Bill Act.

  • May 28, 2025

    4 Big Questions Raised By International Retaliatory Tax In GOP Bill

    Republicans' evolving international retaliatory tax proposal has been viewed as an effort to influence foreign tax regimes and as a possible tool in global tax and trade talks, but it has sparked concerns that it could escalate a trade war or otherwise hurt the U.S. economy. Here, Law360 explores four questions raised by the proposal.

  • May 28, 2025

    $3.9 Trillion Price Tag On House Budget Bill's Tax Provisions

    Tax provisions included in the House-passed budget reconciliation bill that would extend and make permanent many provisions in the 2017 tax overhaul would cost $3.9 trillion over the next decade, according to a report released Wednesday by the Joint Committee on Taxation.

  • May 28, 2025

    Mexico Collected $982M From Transfer Pricing Last Year

    Mexico's transfer pricing regime collected 19 billion pesos ($980 million) from large businesses last year, part of a trend that has seen the country's transfer pricing revenue more than triple over the past five years compared with the prior five-year period, its tax administration said.

  • May 28, 2025

    One Convicted For Role In €195M VAT Fraud Scheme

    A Munich court convicted a man for his role in a value-added tax fraud scheme that spanned 17 countries and caused an estimated €195 million ($220 million) in damages, the European Public Prosecutor's Office said Wednesday.

Expert Analysis

  • Mentorship Resolutions For The New Year

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    Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.

  • Tax Directive Marks Milestone In Harmonizing EU System

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    The Council of the European Union’s recently adopted tax directive is a significant step toward streamlining and modernizing procedures for member states, and will greatly reduce administrative burden and compliance costs for cross-border investors, says Martin Phelan at Simmons & Simmons.

  • 5 Litigation Funding Trends To Note In 2025

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    Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.

  • Rethinking Litigation Risk And What It Really Means To Win

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    Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.

  • Small Biz Caught In Corporate Transparency Act Crossfire

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    Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.

  • No, Litigation Funders Are Not 'Fleeing' The District Of Del.

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    A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.

  • 5 E-Discovery Predictions For 2025 And Beyond

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    In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.

  • What's Ahead As Transparency Act Comes To A Crossroads

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    Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.

  • 7 Ways 2nd Trump Administration May Affect Partner Hiring

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    President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.

  • E-Discovery Quarterly: Rulings On Custodian Selection

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    Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.

  • Exploring Venue Strategy For Trump-Era Regulatory Litigation

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    Litigation will likely play a prominent role in shaping policy outcomes during the second Trump administration, and stakeholders have several tools at their disposal to steer regulatory litigation toward more favorable venues, say attorneys at Covington.

  • An Associate's Guide To Career Development In 2025

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    As the new year begins, associates at all levels should consider establishing career metrics, fostering key relationships and employing other specific strategies to help move through the complexities of the legal profession with confidence and emerge as trailblazers, say EJ Stern and Amanda George at Fractional Law Firm.

  • Making The Pitch To Grow Your Company's Legal Team

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    In a compressed economy, convincing the C-suite to invest in additional legal talent can be a herculean task, but a convincing pitch — supported by metrics and cost analyses — may help in-house counsel justify the growth of their team, say Elizabeth Smith and Roger Garceau at Major Lindsey.

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