International

  • March 20, 2026

    Duane Morris Bolsters SF Team With Hanson Bridgett Hire

    Duane Morris LLP is growing its West Coast team, bringing in a Hanson Bridgett LLP transactions attorney as a partner in its San Francisco office.

  • March 20, 2026

    Aussie Tax Agency Says Pepsi's Court Win Has Limited Reach

    A ruling from Australia's top court that sided with Pepsi in a long-running tax dispute is likely to have limited applications to other cases because of the beverage giant's uncommon facts, according to the Australian Taxation Office.

  • March 20, 2026

    Taxation With Representation: Clifford Chance, Davis Polk

    In this Week's Taxation With Representation, Public Storage acquires National Storage Affiliates Trust, 3M teams up with Bain Capital to buy Madison Fire & Rescue, and Mastercard acquires stablecoin infrastructure firm BVNK.

  • March 20, 2026

    Paris Firm Adds Longtime Transfer Pricing Expert

    De Gaulle Fleurance, a Paris firm specializing in business law, has boosted its international tax department with the addition of a longtime expert in transfer pricing.

  • March 19, 2026

    Meta Says IRS Defying Settled Facts In $16B Tax Fight

    The IRS is refusing to agree to the truth of parts of the trial transcript and the U.S. Tax Court's opinion last year in a Facebook transfer pricing case as the social media platform's parent, Meta, disputes a $16 billion tax bill in a related case, the company told the court.

  • March 19, 2026

    Tariff Refund System Testing Underway, US Customs Says

    The program for U.S. importers to claim refunds for tariffs paid under the global regime struck down by the U.S. Supreme Court is undergoing testing, according to a declaration by a Customs and Border Protection official filed Thursday.

  • March 19, 2026

    Texas Court Erases $7.8M In Taxes On Stored Export Oil

    A Texas company storing presold crude oil to be exported to foreign countries was wrongly taxed $7.8 million by a county assessor, a state appeals court ruled Thursday, reversing a trial court decision.

  • March 19, 2026

    EU Trade Committee Approves US Trade Deal With Conditions

    The European Parliament's trade committee approved major tariff cuts Thursday to implement the bloc's U.S. trade deal, but made the cuts contingent on President Donald Trump respecting a 15% cap on rates, lowering steel and aluminum tariffs and not imposing tariffs over foreign policy concerns.

  • March 19, 2026

    Affiliated Cos. Not Automatically Linked, EU High Court Says

    Businesses are not automatically linked for the purposes of determining state aid eligibility merely because an individual holds a majority stake in each of them, the European Court of Justice said Thursday in a dispute between a Latvian company and the country's tax authorities.

  • March 19, 2026

    EU Official Says Tax Simplification Requires Trade-Offs

    A top tax official in the European Union's executive body said Thursday that EU countries must be prepared to make some trade-offs, for instance on information exchange and information technology investment, if they want to achieve tax simplification.

  • March 19, 2026

    HMRC Proposes Stricter Transaction Reporting For Small Cos.

    The U.K.'s tax authority wants to hear from small businesses about plans to require entities to disclose close company transactions such as cash withdrawals to it as part of an effort to reduce tax compliance failures, the agency said Thursday.

  • March 18, 2026

    Temu Users Join Customer Push For IEEPA Tariff Refunds

    Online marketplace Temu must refund customers for passed-on costs related to the Trump administration's now-invalidated International Emergency Economic Powers Act tariffs, a consumer leading a proposed nationwide class action told an Illinois state court.

  • March 18, 2026

    Malawi Can Resume Discovery On Gem Co. In Tax Dispute

    Malawi can resume discovery on a gem mining company it has accused of dodging billions of dollars in taxes, as a Washington federal court said Wednesday that the country had identified errors in the court's previous order to halt the process.

  • March 18, 2026

    Cos. Can Undo Exception To Limit On Biz Interest Deduction

    Guidance from the Internal Revenue Service issued Wednesday described how companies can reverse the decision to elect out of the limitation on business interest deductions under Internal Revenue Code Section 163(j).

  • March 18, 2026

    France Wants Digital Tax On US Firms In EU Budget

    France wants the European Union to create a digital services tax targeting U.S. firms to help fund the bloc's next budget, a French official said during an EU meeting.

  • March 18, 2026

    EU Calls For Progress On Stalled Tax Harmonization Plans

    The European Commission called for progress Wednesday on tax harmonization proposals that are stuck in the legislative pipeline, saying it is seeking to remove barriers to companies operating in the European Union.

  • March 18, 2026

    HMRC Counters Barclays Bid To Revive £800M Tax Deduction

    Barclays Bank wasn't entitled to treat as a corporate tax deduction £800 million ($1 billion) of £3 billion raised issuing debt instruments in a deal with Qatar and Abu Dhabi, HM Revenue & Customs argued Wednesday, because the bank gave away certain securities as a "sweetener" for the deal.

  • March 17, 2026

    $20M FBAR Judgment Didn't Need Jury Trial, Judge Says

    A Florida federal court should reject a U.S.-German citizen's effort to escape a nearly $20 million tax judgment for failing to report foreign bank account information, a magistrate judge suggested, rejecting the man's argument that he was wrongly deprived of a jury trial.

  • March 17, 2026

    Barclays Defends £800M Deduction For Financial Crisis Debt

    Barclays Bank defended its tax treatment of £3 billion ($4 billion) in debt instruments issued during the financial crisis, telling the U.K. Upper Tribunal on Tuesday that £800 million should be deductible as a debit arising from a loan.

  • March 17, 2026

    US Minimum Tax Deal Has Clear Drawbacks, UK Official Says

    There are clear drawbacks to U.S. companies escaping the global minimum tax's international reach as the result of an agreement reached under pressure from the U.S. government, panelists said Tuesday.

  • March 17, 2026

    WTO Must Extend Digital Trade Protections, Lawmakers Told

    The World Trade Organization's moratorium on digital trade measures must be extended and its scope strengthened in support of U.S. business interests, experts testifying before the U.S. House's trade panel told lawmakers Tuesday.

  • March 17, 2026

    Treasury Official Urges Careful Deliberation On Digital Taxes

    Global players should prioritize consensus and constructive dialogue when it comes to tax reform rather than rushing into unilateral measures such as digital service taxes, the U.S. Department of the Treasury's top delegate to the OECD said Tuesday.

  • March 17, 2026

    Director Owing £120K Tax Banned For 'Abusive Phoenixism'

    A business adviser who repeatedly set up new firms that left unpaid tax bills has been banned as a director for five years after his consultancy collapsed owing more than £120,000 ($160,000).

  • March 16, 2026

    New Int'l Tax Rules May Spur State Apportionment Arguments

    A major change in taxation of international income may present a bolstered argument for companies seeking alternative apportionment in states, tax professionals said Monday.

  • March 16, 2026

    Brokerage Lacks NY Ties In Pensions' Tax Claims, Judge Says

    A New York federal court threw out claims by three pension plans against a London brokerage firm that, according to the plans, executed fraudulent refund claims for them to the Danish tax authority, finding the brokerage had insufficient ties to New York.

Expert Analysis

  • How Attys Can Use AI To Surface Narratives In E-Discovery

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    E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.

  • AbbVie Frees Taxpayers From M&A Capital Loss Limitations

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    The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.

  • ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'

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    The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.

  • Can Companies Add Tariffs Back To Earnings Calculations?

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    With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.

  • A Look At DOJ's Dropped Case Against Early Crypto Operator

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    The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.

  • 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.

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