International

  • February 02, 2026

    OECD Amends Tax Treaty Manual To Up Dispute Resolution

    The Organization for Economic Cooperation and Development is updating guidance for tax treaties to strengthen tax treaty mechanisms for preventing cross-border tax disputes, according to a statement Monday.

  • February 02, 2026

    EU Loses €14B In Taxes Annually From US Cos., Report Says

    European Union member states are losing €14 billion ($16.5 billion) in revenues each year as a result of tax avoidance by U.S. companies, Tax Justice Network warned Monday ahead of international tax talks.

  • February 02, 2026

    Norton Rose Grows In Key Cities By Adding 5 Polsinelli Attys

    Norton Rose Fulbright announced Monday that it has added five former Polsinelli PC shareholders as partners to grow its transactional and healthcare capabilities in two key U.S. markets.

  • January 30, 2026

    3 Things To Keep In Mind About IRS' Corporate Audit Changes

    The IRS' revamped audit process for corporate taxpayers will likely streamline examinations, but companies may now shoulder new responsibilities when presenting facts and face lingering uncertainties when weighing whether to participate in a broadened settlement program. Here, Law360 examines three key issues for companies to consider under the new audit process.

  • January 30, 2026

    US Rebukes WTO Siding With China On Energy Tax Credits

    The U.S. Trade Representative condemned the World Trade Organization's decision to side with China in a dispute over energy tax credits passed during former President Joe Biden's term Friday, calling the global body's dispute resolution mechanism inadequate.

  • January 30, 2026

    DOJ Seeks Halliburton's Legal Memo In $35M Tax Fight

    Halliburton has overblown its attorney-client privilege claims over a set of key legal documents the U.S. Department of Justice wants the global oil field operator to disclose as part of the company's $35 million tax refund dispute, the DOJ told a Texas federal court.

  • January 30, 2026

    Taxation With Representation: Clifford Chance, Ropes & Gray

    In this week's Taxation With Representation, real estate investment trust Apollo Commercial Real Estate Finance Inc. announces plans to sell a loan portfolio to retirement services company Athene Holding Ltd., engineering and technology company Leidos acquires Entrust Solutions Group, and Prosperity Bancshares Inc. and Stellar Bancorp Inc. announce a merger.

  • January 30, 2026

    EU Presses 10 Members To Implement Min. Tax Info Rules

    The European Union's executive arm issued warnings Friday to 10 member countries, including Belgium, Cyprus and Sweden, for failing to fully implement the bloc's tax transparency rules for the global minimum tax.

  • January 30, 2026

    EU Calls On 12 Countries To Impose Crypto Tax Rules

    The European Commission is warning 12 countries, including Bulgaria, Czechia and Spain, to extend the European Union's tax transparency rules for crypto-assets, the commission said Friday.

  • January 29, 2026

    Congress' Limited Tariff Role May Persist After Justices Rule

    The U.S. Supreme Court's ruling on President Donald Trump's emergency tariffs could leave the door open for Congress to play a larger role in trade policy heading into November's midterms, but that opportunity may pose few political incentives for lawmakers.

  • January 29, 2026

    8th Circ.'s Ruling For 3M 'Makes No Sense,' Gov't Says

    The Eighth Circuit's ruling that Brazilian law prevented the IRS from reallocating income to 3M from its subsidiary in that country "makes no sense" because the law limits only royalties, not other forms of income, the government argued Thursday in seeking a rehearing by the full court.

  • January 29, 2026

    What Makes A Good Tax Court Expert? Economists Share Tips

    It's not easy being an expert witness in a U.S. Tax Court case. Lawyers ask leading questions and bring up old research; hypothetical scenarios abound, requiring analysis on the fly; and judges have varying levels of expertise, with some seeking detailed explanation and others offended by it.

  • January 29, 2026

    Imported Scooters Not Duty-Free, UK Court Says In Reversal

    Mobility scooters imported into the U.K. by two companies should be assessed a 10% duty, a London court ruled, reversing a lower court decision it said labeled the scooters duty-free due to a misapplication of relevant rules.

  • January 29, 2026

    Fund Managers Should Be Taxed As Workers, HMRC Testifies

    Portfolio managers at BlueCrest Capital Management should be taxed as disguised employees because they don't hold wider legal responsibilities at the hedge fund, Britain's tax authority told the U.K. Supreme Court on Thursday.

  • January 29, 2026

    Australia Issues Tax Reporting Rules For Large Private Cos.

    The Australian Taxation Office issued guidance Thursday for large, privately owned entities to report if they qualify for certain stringent tax integrity measures as well as possible higher penalties.

  • January 29, 2026

    SocGen Loses Case Against French Electric Grid Fees

    A European Union court upheld fees that French companies must pay to access the country's electric grid, ruling against banking giant Société Générale in holding that the payments don't amount to indirect excise taxes that would flout EU law.

  • January 29, 2026

    Microsemi To Report $144M In Overseas Sales In Settlement

    Semiconductor manufacturer Microsemi has agreed to report $144 million in income from sales to its Irish affiliate but will avoid some tax penalties under the terms of a transfer pricing settlement with the Internal Revenue Service, according to a filing in the U.S. Tax Court.

  • January 29, 2026

    5 Indicted In €20M VAT Fraud Involving 'Designer Fuels'

    The European Public Prosecutor's Office indicted five people in Luxembourg suspected of committing €20 million ($23.9 million) in value-added tax fraud through a criminal scheme that traded in what are known as designer fuels, it said Thursday.

  • January 28, 2026

    Tax Court Rejects Aventis' Securitizing Debt Assets

    Pharmaceutical giant Aventis Inc. is ineligible for a favorable tax treatment on its securitization of financial assets, the U.S. Tax Court ruled Wednesday, finding the company did not comply with statutory requirements and failed to show it was not the beneficial owner of the assets.

  • January 28, 2026

    Fund Managers Should Be Taxed As Partners, UK Court Told

    Portfolio managers at a hedge fund should be taxed as partners, not disguised employees, because they have significant influence at the partnership, a hedge fund told the U.K. Supreme Court on Wednesday.

  • January 28, 2026

    Tax Group Of The Year: Skadden

    Skadden Arps Slate Meagher & Flom LLP's tax practice guided several major cases and deals this past year, including representing drugmaker Amgen Inc. in one of the largest transfer pricing cases litigated last year, earning the firm a spot among the 2025 Law360 Tax Groups of the Year.

  • January 28, 2026

    Gov't Escapes Bad Faith Sanctions In FBAR Dispute

    A New York federal judge declined Wednesday to sanction the U.S. government in its suit against the estate of a businessman over undisclosed offshore bank accounts, holding that his widow failed to show the government acted in bad faith.

  • January 28, 2026

    Denmark Looking To Cut Food Taxation By $961M With Deal

    The Danish government and its various political parties have agreed to work on a plan to cut 6 billion kroner ($959 million) in value-added taxes on food annually starting in 2028, its finance ministry said Wednesday.

  • February 04, 2026

    Ropes & Gray Adds 10-Lawyer Linklaters Team In Paris

    Ropes & Gray LLP has recruited a team of 10 lawyers from Linklaters LLP for its new office in Paris as it seeks to boost its services to clients in private funds and tax matters in Europe and worldwide.

  • February 12, 2026

    Law360 Seeks Members For Its 2026 Editorial Boards

    Law360 is looking for avid readers of our publications to serve as members of our 2026 editorial advisory boards.

Expert Analysis

  • 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.

  • Attacks On Judicial Independence Tend To Manifest In 3 Ways

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    Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.

  • Section 899 Could Be A Costly Tax Shift For US Borrowers

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    Intended to deter foreign governments from applying unfair taxes to U.S. companies, the proposal adding new Section 899 to the Internal Revenue Code would more likely increase tax burdens on U.S. borrowers than non-U.S. lenders unless Congress limits its scope, says Michael Bolotin at Debevoise.

  • Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use

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    The recent revelation that a handful of questions from the controversial California bar exam administered in February were drafted using generative artificial intelligence demonstrates the continued importance of disclosure for attorneys who use AI tools, say attorneys at Troutman.

  • In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable

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    The U.S. District Court for the Eastern District of Virginia was again one of the fastest civil trial courts in the nation last year, and an interview with the court’s newest judge provides insights into why it continues to soar, says Robert Tata at Hunton.

  • How Attorneys Can Become Change Agents For Racial Equity

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    As the administration targets diversity, equity and inclusion efforts and law firms consider pulling back from their programs, lawyers who care about racial equity and justice can employ four strategies to create microspaces of justice, which can then be parlayed into drivers of transformational change, says Susan Sturm at Columbia Law School.

  • Adapting To Private Practice: From US Attorney To BigLaw

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    When I transitioned to private practice after government service — most recently as the U.S. attorney for the Eastern District of Virginia — I learned there are more similarities between the two jobs than many realize, with both disciplines requiring resourcefulness, zealous advocacy and foresight, says Zach Terwilliger at V&E.

  • The Ins And Outs Of Consensual Judicial References

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    As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.

  • The BigLaw Settlements Are About Risk, Not Profit

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    The nine Am Law 100 firms that settled with the Trump administration likely did so because of the personal risk faced by equity partners in today's billion‑dollar national practices, enabled by an ethics rule primed for modernization, says Adam Forest at Scale.

  • Customs Fraud Enforcement In The Age Of Tariffs

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    In the wake of the Trump administration’s new approach toward tariffs, two recent Justice Department developments demonstrate aggressive customs fraud enforcement, with the DOJ emphasizing competitive harm to American businesses, and signaling that investigations will likely involve both civil and criminal enforcement tools, say attorneys at Bernstein Litowitz and London & Naor.

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