International

  • January 07, 2026

    Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says

    The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed Swiss account, the Second Circuit said Wednesday, upholding a lower court's judgment.

  • January 07, 2026

    Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies

    The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025.

  • January 07, 2026

    Gov't Slow-Rolling Lower Fee For Expatriation, Court Told

    The U.S. State Department has impermissibly slow-walked the rollout of a reduced fee for renouncing U.S. citizenship, a Paris-based group that represents Americans permanently residing abroad told a D.C. federal court.

  • January 07, 2026

    Australia Increasingly Blocking Tax Debtors From Leaving

    The Australian Taxation Office is increasingly barring international travel for people with tax debts who it suspects of trying to flee their obligations, it said Wednesday.

  • January 07, 2026

    IRS Mulling Budget Bill's Changes To CFC Rules, Official Says

    The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.

  • January 07, 2026

    Irish Tax Revenue Up €8.6B In 2025, Corp. Taxes Up 17%

    The Irish government saw tax revenue rise by €8.6 billion ($10 billion) in 2025, with corporate tax receipts up by 17.2%, the Department of Finance said in its annual report.

  • January 07, 2026

    Portuguese Tax System Too Complex, OECD Says

    The Portuguese government needs to simplify the country's tax regime to boost economic growth and raise living standards, the Organization for Economic Cooperation and Development said Wednesday.

  • January 07, 2026

    IRS Outlines Process For PFICs Seeking Retroactive Elections

    The Internal Revenue Service set out requirements Wednesday for passive foreign investment corporations seeking rulings to allow them to make retroactive qualified electing fund elections.

  • January 06, 2026

    IRS Appeals Pause Of ICE Info-Sharing Agreement

    The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.

  • January 06, 2026

    Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules

    A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasion that would justify the regulations.  

  • January 06, 2026

    Thai Cabinet OKs Changes To Aid Satisfying Global Min. Tax

    Thailand's Cabinet has approved draft legislation aimed at helping companies comply with the 15% global minimum tax, the country's tax authority said.

  • January 06, 2026

    Uber Changes UK Contracts Over New Minicab VAT Rules

    Uber has changed its contracts with its British drivers to reclassify itself as an agent, a move that will save it from collecting value-added tax on fares, just before the U.K.'s overhaul of tax rules for the minicab sector took effect.

  • January 06, 2026

    Ireland Offers Europe's First Tax Break For Unscripted Shows

    Ireland is offering a corporate tax credit for unscripted productions that promote Irish and European culture, the Department of Finance said, noting that the initiative is the first of its kind in Europe.

  • January 06, 2026

    Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team

    After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on the tax elements of mergers and acquisitions.

  • January 05, 2026

    Md. Railway Distributor Exec Sued Over Alleged Asset Looting

    Chinese railway equipment manufacturer Anyang Railway Equipment Co. Ltd. has filed suit in Maryland federal court, claiming the sole executive and majority shareholder of a railway distribution company, in which Anyang is also a shareholder, looted corporate assets for personal gain and excluded Anyang from management decisions, among other things.

  • January 05, 2026

    EU Sets Default Emission Levels For Carbon Border Tax

    The European Union released default levels of greenhouse gas emissions that importers must use to calculate liabilities for the newly enforced carbon border adjustment mechanism when they lack reliable information on the emissions associated with producing covered products.

  • January 05, 2026

    Countries Reach Deal To Exempt US From Pillar 2 Tax

    Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.

  • January 05, 2026

    ECJ To Mull Parent-Subsidiary Directive's Tax Impact

    The European Union's top court will rule on the tax implications of the EU's parent-subsidiary directive for a loss-making company in Germany following a request from the country's finance court, according to a Monday notice.

  • January 05, 2026

    Gibson Dunn Adds Sidley Tax Pro In Silicon Valley

    Gibson Dunn & Crutcher LLP announced Monday that it has bulked up its tax practice group with a partner in Palo Alto, California, who previously co-led the global tax practice and headed up the West Coast tax group at Sidley Austin LLP.

  • January 02, 2026

    Busy DOJ Tax Atty Seeks More Time In 7th Circ. AbbVie Case

    A U.S. Department of Justice tax attorney asked the Seventh Circuit on Friday for another extension to file an opening brief in a dispute over AbbVie's $1.6 billion payment to an Irish biotechnology company, citing staffing shortages and internal procedural requirements.

  • January 02, 2026

    IRS Floats Updates To Fee Paid By Brand Drugmakers

    The Internal Revenue Service floated updates to regulations governing how branded prescription drug manufacturers or importers should calculate an annual fee established by the Affordable Care Act, a move the agency said aims to incorporate changes in drug discount programs and clarify tax reporting.

  • January 02, 2026

    Federal Tax Policy To Watch In 2026

    Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.

  • January 02, 2026

    Top Federal Tax Cases To Watch In 2026

    The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.

  • January 02, 2026

    European Tax Policy To Watch In 2026

    The European Union may have to take a more independent line on international tax in 2026 as it tackles policies such as the minimum corporate tax, but its success will likely depend on how it deals with opposition to such policies from the U.S. administration. Here, Law360 looks at important European tax developments to watch for the coming year.

  • January 02, 2026

    Top International Tax Policy To Watch In 2026

    The details of a proposed U.S. exemption from the global minimum tax's international provisions, possible retaliatory measures by the U.S. government and the rollout of major changes in Congress' latest budget are high priority for tax professionals going into 2026. Here, Law360 previews international tax practitioners' top priorities for the coming year.

Expert Analysis

  • 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.

  • Advice For 1st-Gen Lawyers Entering The Legal Profession

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    Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.

  • Trump Tax Law's Most Impactful Corp. And Individual Changes

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    The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.

  • From Clerkship To Law Firm: 5 Transition Tips For Associates

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    Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.

  • Trump Tax Law's Most Consequential International Changes

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    The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.

  • Associates Can Earn Credibility By Investing In Relationships

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    As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.

  • Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling

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    The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.

  • What 2 Profs Noticed As Transactional Law Students Used AI

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    After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.

  • BigLaw Settlements Should Not Spur Ethics Deregulation

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    A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.

  • 5 Ways Lawyers Can Earn Back The Public's Trust

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    Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.

  • Legal Jeopardy Looms Over Trump's Trade Negotiation Plans

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    Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.

  • What US-India Trade Deal Will Mean For Indian Pharma

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    Complicated by newly imposed tariffs from the U.S., the outcome of the U.S.-India trade talks is poised to reshape not just trade policy, but also the strategic alignment of the two countries' pharmaceutical ecosystems, says Jashaswi Ghosh at Holon Law Partners.

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