International

  • October 22, 2025

    Australia Issues Guidance For Minimum Tax Safe Harbor

    Australia released guidance Wednesday detailing when companies can forgo detailed top-up tax calculations for a jurisdiction under a safe harbor for the 15% global minimum tax that is based on country-by-country reporting.

  • October 22, 2025

    US Among Few Places With Amount B Rules, OECD Reports

    The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.

  • October 22, 2025

    'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says

    Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.

  • October 22, 2025

    Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling

    Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.

  • October 22, 2025

    Trade Court OKs $235K Tax Bill On Korean Soju Imports

    South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.

  • October 22, 2025

    Canada Tax Agency Could Expand Audit Powers, Pro Says

    Tax attorneys in Canada are closely watching a proposal that would give the country's revenue agency extensive audit powers, including the ability to take information under oath before any potential litigation begins, a practitioner said Wednesday.  

  • October 22, 2025

    Switzerland Seeks Comments On Updated EU Tax Data Deal

    The Swiss government is inviting public comments on an agreement it reached with the European Union to update the jurisdictions' agreement for the automatic exchange of tax information, it said Wednesday.

  • October 21, 2025

    Discovery Against Gem Company Halted In Malawi's Tax Probe

    Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.

  • October 21, 2025

    'Revenge Tax' May Reappear If Pillar 2 Talks Stall, Pros Say

    Republican lawmakers are likely to revive what is commonly known as the revenge tax if countries are unable to flesh out a tentative agreement to effectively exempt U.S. companies from the 15% global corporate minimum tax regime known as Pillar Two, practitioners said Tuesday.

  • October 21, 2025

    EU To Ditch Plans For Transaction Tax, Shell Co. Law

    The European Commission plans to withdraw proposed directives that would impose a financial transaction tax and target tax evasion through the use of shell companies, it said Tuesday in a work program for 2026.

  • October 21, 2025

    Medtronic Says 8th Circ. Wrongly Tossed Tax Court's Method

    The Eighth Circuit's rejection of the U.S. Tax Court's latest ruling on the pricing of Medtronic intangibles placed unnecessary restrictions on the court's unspecified method addressing such assets transferred to Puerto Rico, the company argued as it asked the circuit court to rethink its decision.

  • October 21, 2025

    UK Pensions Body Calls For Long-Term Tax Policy

    The government must commit to long-term policy on pension tax relief, an influential trade body said Tuesday, warning that mounting uncertainty every year around the Budget was harming consumer confidence.

  • October 20, 2025

    G7 Deal Exempting US From Min. Tax Hurts Brazil, Prof Says

    Latin American countries, especially Brazil, are concerned that the deal announced by the Group of Seven countries in June exempting U.S. multinationals from a globally agreed 15% minimum tax gives the U.S. an unfair advantage over them, a professor at University of Antwerp said Monday.

  • October 20, 2025

    Emergency Tariffs Unlawfully Unprecedented, Justices Told

    The International Emergency Economic Powers Act has never been used until President Donald Trump to impose tariffs, and nowhere does the law provide that explicit authority, a dozen states, several small businesses and a pair of Illinois toymakers told the U.S. Supreme Court Monday.

  • October 20, 2025

    Switzerland, EU Sign Automatic Tax Data Exchange Deal

    The Swiss government signed an agreement with the European Union to improve its automatic exchange of financial information standards, according to a statement published Monday.

  • October 20, 2025

    Brazil Signs OECD Convention On Tax Treaties

    Brazil on Monday signed the Organization for Economic Cooperation and Development's convention to align bilateral tax treaties with standards aimed at preventing base erosion and profit shifting, according to the organization.

  • October 20, 2025

    Treasury Floats Plan To Scrap Look-Through Rules

    The U.S. Treasury Department proposed regulations Monday that would remove rules that allow revenue officials to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.

  • October 20, 2025

    China To Offer 50% VAT Rebate For Offshore Wind Electricity

    China will offer a 50% rebate on value-added taxes for companies that sell electricity they produce with offshore wind installments starting next month, the State Tax Administration said.

  • October 20, 2025

    Directors Jailed For £20M Fraud Involving Fake VAT Claims

    Six company directors were sentenced Monday for their role in a £20 million ($27 million) tax fraud involving a wholesale electrical appliance business that deliberately understated how much value-added tax was owed to HM Revenue and Customs.

  • October 17, 2025

    Trump Orders Truck Tariffs, Expands Auto Rebate Program

    President Donald Trump signed an executive order Friday to begin anticipated tariffs on heavy and medium trucks on Nov. 1, while expanding a program that domestic auto manufacturers are already utilizing for rebates to existing tariffs on auto vehicles.

  • October 17, 2025

    Electronic Co. Tells Justices Trump Tariffs Are The Emergency

    Emergency tariffs imposed by President Donald Trump are creating extraordinary economic threats under a law that was intended to protect U.S. retailers from such harm, a Virginia-based electronics company told the U.S. Supreme Court on Friday.

  • October 17, 2025

    UN Shipping Agency Delays Carbon Price Opposed By US

    The United Nations' shipping agency agreed Friday to postpone for one year its plan to introduce a global carbon price, which the U.S. government opposes, having called it a "global carbon tax."

  • October 17, 2025

    Covington Adds Former IRS Special Counsel In DC

    Covington & Burling LLP has grown its tax practice in Washington, D.C., with the addition of a former special counsel in the Office of Chief Counsel at the Internal Revenue Service.

  • October 17, 2025

    French Digital Tax Ruling Puts Spotlight On Trade Tensions

    A French court decision that upheld the nation's digital services tax could bolster similar measures in other European Union member states, but legal backing may mean little if countries use DSTs as bargaining chips in tariff negotiations with the United States.

  • October 17, 2025

    Taxation With Representation: Latham, Kirkland, Wachtell

    In this week's Taxation With Representation, the Artificial Intelligence Infrastructure Partnership, MGX, and BlackRock's Global Infrastructure Partners acquire Aligned Data Centers from Macquarie Asset Management and co-investors; Rayonier Inc. and PotlatchDeltic Corp. merge to create a timber and wood products giant; and a Lone Star Funds affiliate acquires industrial processing equipment provider Hillenbrand Inc.

Expert Analysis

  • Evaluating The Current State Of Trump's Tariff Deals

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    As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.

  • How Hyperlinks Are Changing E-Discovery Responsibilities

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    A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.

  • Preserving Refunds As Tariffs Await Supreme Court Weigh-In

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    In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.

  • Writing Musicals Makes Me A Better Lawyer

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    My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.

  • Adapting To Private Practice: From Va. AUSA To Mid-Law

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    Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.

  • 7 Document Review Concepts New Attorneys Need To Know

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    For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

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    As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.

  • Opportunity Zone's Future Corp. Tax Benefits Still Uncertain

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    Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.

  • How GILTI Reform Affects M&A Golden Parachute Planning

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    Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.

  • Demystifying The Civil Procedure Rules Amendment Process

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    Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.

  • Parenting Skills That Can Help Lawyers Thrive Professionally

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    As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.

  • Trump Tax Law's Most Impactful Energy Changes

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    The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.

  • Adapting To Private Practice: From Texas AUSA To BigLaw

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    As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.

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