International

  • March 14, 2025

    Taxation With Representation: Davis Polk, Paul Weiss

    In this week's Taxation With Representation, Mallinckrodt PLC and Endo Inc. combine, Rocket Cos. buys Redfin, and Endo divests its international pharmaceuticals business to Knight Therapeutics Inc.

  • March 14, 2025

    Struck-Off Lawyer Can't Lift Ban After Misleading HMRC

    A former consultant solicitor who misled HM Revenue and Customs to get a refund on stamp duty land tax has failed to have his professional ban lifted as a London court ruled on Friday that the sanction was fair and justified.

  • March 13, 2025

    Texan Calls $1.7M In FBAR Penalties Unconstitutional

    Constitutional law bars the United States from imposing $1.7 million in penalties for failure to report foreign bank accounts, a Texan said in urging a federal court to dismiss such an assessment against her.

  • March 13, 2025

    Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told

    The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.

  • March 13, 2025

    Australia Clarifying Managed Investment Trust Tax Regime

    The Australian government is planning to update its income tax laws to make it clear that trusts ultimately owned by a foreign pension fund can use certain concessional withholding tax rates on eligible distributions to members, the country's assistant treasurer said Thursday. 

  • March 13, 2025

    Belgian Firm Can Nix Dividends From Tax Base, Court Rules

    A Belgian engineering company was entitled to reduce its tax base by excluding dividends from its subsidiaries in member states before taxation, as per EU law and contrary to Belgian law, the Court of Justice of the European Union said in a preliminary ruling Thursday.

  • March 13, 2025

    Former IRS Counsel Joins Hinshaw In Chicago

    Hinshaw & Culbertson LLP announced that a longtime government attorney who most recently served as deputy managing counsel of the Internal Revenue Service Office of Chief Counsel in Chicago, has joined the firm's government practice as a partner.

  • March 13, 2025

    Akin's Energy Transition Group Grows With V&E Tax Atty

    Akin Gump Strauss Hauer & Feld LLP has hired a Vinson & Elkins LLP tax counsel who has spent the past decade counseling clients on the federal income tax aspects of energy transition transactions, the firm announced Thursday.

  • March 13, 2025

    5th Circ. Asks If Enforcement Delay Affects CTA Challenge

    The Fifth Circuit has asked for supplemental briefing in a challenge against the Corporate Transparency Act, asking whether the case is affected by the U.S. Treasury Department's recent decision to suspend enforcement of reporting rules for domestic companies.

  • March 13, 2025

    Trump's EU Threat May Aim To Boost Negotiation Leverage

    President Donald Trump continued his trade tactics Thursday, threatening a 200% tariff on European alcohol imports that is almost certain to be another tool to leverage in future negotiations despite the economic uncertainty it creates.

  • March 13, 2025

    Funding Deficiency May Hinder UN Tax Talks, Group Says

    Governments interested in pursuing a United Nations tax convention should step up funding for the organization, which is facing a budget shortfall, according to the Tax Justice Network, as U.S. arrears drag on quicker-than-usual funding from other countries.

  • March 13, 2025

    Insurance Brokers Could Get Tax Refunds After Court Ruling

    U.K. insurance brokers could be in line for tax refunds from the state worth up to £400 million ($518 million) after a landmark court case, according to accountancy MHA.

  • March 13, 2025

    Wait To File Taxes If You Have Capital Gains, Canada Says

    The Canada Revenue Agency recommended that taxpayers with capital gains wait to file their tax returns as it finalizes updates to its system to account for the delayed proposed increase in the inclusion rate, saying it will waive late-filing penalties.

  • March 12, 2025

    OECD Calls On Costa Rica To Limit Regressive Exemptions

    Costa Rica's tax revenue makes up just 25% of the country's gross domestic product, thanks in part to regressive exemptions to value-added and personal income taxes and its overall narrow tax bases, the Organization for Economic Cooperation and Development said.

  • March 12, 2025

    Judge Tosses Tax Fraud Claim In Mariana Bribery Case

    A federal court dismissed Wednesday a claim connected to allegations of tax fraud in a $310,000 civil asset forfeiture case brought by the U.S. government against a Northern Mariana Islands business after concluding the court lacked jurisdiction.

  • March 12, 2025

    Starbucks' Sourcing Aided $1.3B Low-Tax Profits, Report Says

    Starbucks leveraged its private certification program for coffee growers to boost profits transferred almost tax-free from Switzerland to the Netherlands to the U.K., amounting to an estimated $1.3 billion between 2011 and 2021, according to a report from a union-funded nonprofit organization.

  • March 12, 2025

    Tariffs Prompt Chipmakers To Look At Manufacturing Moves

    The U.S. semiconductor industry is considering moving manufacturing operations to the U.S. and elsewhere as a tariff-mitigation strategy with President Donald Trump threatening to levy the sector and its supply chains, professionals told Law360.

  • March 12, 2025

    EU E-Commerce Group Calls For Extended DST Moratorium

    The expiration of an agreement pausing implementation of digital services taxes comes as the entirety of the OECD's two-pillar agreement on international taxes leaves impacted businesses in uncertain waters, a European Union business group said in a letter, seeking an extension of the moratorium.

  • March 12, 2025

    EU Targets US Goods In Response To Trump's Tariffs

    The European Commission said Wednesday that it will impose tariffs on American goods imported into the European Union in response to U.S. tariffs placed on EU steel and aluminum exports.

  • March 12, 2025

    Spain Referred To CJEU Over Nonresident Tax Treatment

    Spain will have to face the Court of Justice of the European Union over what the European Commission said is a discriminatory capital gains tax regime because of a deferral available to residents that is not available to nonresidents.

  • March 12, 2025

    HMRC To Reward Whistleblowers Who Expose Tax Fraud

    Insiders who tip off investigators to serious tax avoidance by large companies and rich elites will be paid a cut of any money the U.K. tax enforcer claws back under a new policy proposed by the government.

  • March 11, 2025

    Canada's Incoming PM Pledges To Kill Capital Gains Tax Hike

    Canada's newly elected Prime Minister-designate Mark Carney said during his election victory speech that he would spike a controversial proposed increase to the country's capital gains tax, according to local media.

  • March 11, 2025

    Trump, Ontario Back Down After Two-Day Trade Flare-Up

    President Donald Trump called off additional tariffs on Canadian steel and aluminum Tuesday after the Ontario government dropped a briefly imposed surcharge on electricity exports, the White House told Law360 on Tuesday evening. 

  • March 11, 2025

    Retailer Fights US On Overriding Jury In $11.6M FBAR Case

    A federal jury in Hawaii was justified in finding that an international businessman hadn't willfully failed to report his foreign bank accounts in an $11.6 million dispute, and the U.S. government is not entitled to an overruled verdict or new trial, he told the court.

  • March 11, 2025

    Russia Says Guinea Ruling Backs Dismissal In $5B Award Suit

    A recent D.C. federal court decision supports the Russian Federation's bid to dismiss an arbitration enforcement action stemming from a tax dispute with Yukos Capital Ltd., Russia told the same court.

Expert Analysis

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • How Clients May Use AI To Monitor Attorneys

    Excerpt from Practical Guidance
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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

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