International

  • November 25, 2025

    Profit Shifting Signs Persist Despite Waning, OECD Says

    Signs of profit shifting by multinational companies remain persistent despite some abatement over the past several years, the Organization for Economic Cooperation and Development said Tuesday.

  • November 25, 2025

    4 Things To Watch As UK Releases Budget

    The U.K.'s Labour government is set to release an autumn budget Wednesday that faces a test of balancing a pledge not to raise working people's taxes with an expected need to boost revenue to meet fiscal rules. Here are four things to watch for as the budget is issued.

  • November 25, 2025

    IRS To Propose Regs On Repeal Of CFC Tax Year Deferral

    The IRS intends to issue proposed regulations that address the repeal of a provision that allowed a controlled foreign corporation to begin its tax year one month earlier than its majority shareholder in the U.S., the agency said Tuesday.

  • November 25, 2025

    Half A Million Pensioners 'At Risk Of Paying Income Tax'

    An additional half a million state pensioners would pay income tax if the government extends the freeze on thresholds for another two years, a former pensions minister has said.

  • November 24, 2025

    HMRC Updates Guidance For Digital Tax Filings

    HM Revenue & Customs updated guidance Monday for its project to digitalize tax self-assessment, including new guidelines on the digital records regarding income and other information that taxpayers will need to submit.

  • November 24, 2025

    Malaysia's DST Must Avoid Bias Against US, Minister Says

    Malaysia will not impose a digital services tax that discriminates against American companies under its U.S. trade agreement, the country's Minister of Digital told lawmakers Monday, maintaining that this won't restrict the country's sovereignty.

  • November 24, 2025

    AICPA Urges Allowing Barred Foreign Losses For Use In US

    Losses that aren't allowed to reduce tax liabilities abroad should be accepted in the U.S. under rules surrounding dual consolidated losses because they don't cause the dual deductions that those rules aim to prevent, the American Institute of Certified Public Accountants said Monday.

  • November 24, 2025

    G20 Countries Working To Address Pillar 2 Concerns

    Group of 20 nations are negotiating with countries at the Organization for Economic Cooperation and Development to address concerns regarding the 15% global minimum tax agreement known as Pillar Two, G20 leaders announced during their Johannesburg summit.

  • November 21, 2025

    Judge Halts IRS-ICE Info-Sharing Agreement

    A D.C. federal judge temporarily stopped the IRS on Friday from sharing confidential taxpayer addresses with immigration enforcement officials, saying the agency's disclosures of addresses in August under an information-sharing deal were unlawful.

  • November 21, 2025

    IRS Finalizes Stock Buyback Tax Regs Without 'Funding Rule'

    The Internal Revenue Service released final regulations Friday for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule, which would apply the levy to a U.S. subsidiary of a foreign parent company.

  • November 21, 2025

    Trump Excludes Some Brazilian Foods From Higher Tariffs

    President Donald Trump has excluded many Brazilian food products from a 40% tariff, including coffee, cocoa, beef and fruits, after receiving word initial progress has been made in ongoing trade negotiations, according to an executive order.

  • November 21, 2025

    Key Issues Facing The IRS Amid Looming Budget Cuts

    The Internal Revenue Service is facing steep budget cuts in 2026, raising concerns about the agency's ability to handle taxpayer services and enforcement operations that are crucial for bringing in revenue and maintaining compliance with the voluntary system. Here, Law360 looks at the key areas where resource constraints are expected to hamper the IRS and what practitioners can do in response.

  • November 21, 2025

    UK Inheritance Tax Revenue Up 4% So Far In 2025

    The government collected £5.2 billion ($6.8 billion) in inheritance tax between April and October, figures published on Friday by Britain's tax authority show, extending a record-setting trend in the 2025/26 financial year.

  • November 20, 2025

    Importers Left With Uncertainty After US-China Trade Truce

    U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation.

  • November 20, 2025

    Treasury To Curtail Tax Credits For Unauthorized Immigrants

    The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday.

  • November 20, 2025

    EU Needs Unified Tax Benefits For Electricity, Experts Say

    The European Union needs a unified approach to tax benefits that would treat electricity more favorably than fossil fuels amid an impasse surrounding its overhaul to the energy taxation system, experts told the European Parliament's tax committee Thursday.

  • November 20, 2025

    FBAR Penalty Against Ex-Prof Is Constitutional, Court Says

    A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it.

  • November 20, 2025

    EU Council Approves Tax Deal Changes With 5 States

    The Council of the European Union said Thursday that it has approved updates to tax agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland, including new rules to help prevent tax evasion and fraud.

  • November 19, 2025

    Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real

    A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.

  • November 19, 2025

    Tax Court Upholds Rejection Of Tax Tipster's Award

    The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday.

  • November 19, 2025

    Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty

    Governments expressed widespread support for adopting measures to strengthen the mutual agreement procedure within a protocol on dispute resolution in the United Nations tax convention during the latest round of negotiations.

  • November 19, 2025

    Tax Court Substance Ruling Offers Silver Lining For Taxpayers

    Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions.

  • November 19, 2025

    OECD Releases Model Tax Treaty Updates For Amount B

    The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B.

  • November 19, 2025

    EU Tax Compliance Rules Raise €6.8B Annually, EC Finds

    The European Union's directive for administrative cooperation in taxation, known as DAC, has helped tax authorities generate €6.8 billion ($7.8 billion) a year in extra revenue, the European Commission said in a report Wednesday.

  • November 19, 2025

    Trump's Global Tariffs Curtailed Trade, Data Shows

    U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.

Expert Analysis

  • Legal Ethics Considerations For Law Firm Pro Bono Deals

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    If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.

  • 10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks

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    The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.

  • Power To The Paralegals: The Value Of Unified State Licensing

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    Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.

  • 10 Soft Skills Every GC Should Master

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    As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.

  • An Unrestrained, Bright-Eyed View Of Legal AI's Future

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    Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.

  • Tracking The Evolution In Litigation Finance

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    Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.

  • E-Discovery Quarterly: The Perils Of Digital Data Protocols

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    Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.

  • A Cold War-Era History Lesson On Due Process

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    The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.

  • How BigLaw Executive Orders May Affect Smaller Firms

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    Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.

  • Lawsuits Shouldn't Be Shadow Assets For Foreign Capital

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    Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.

  • How To Accelerate Your Post-Attorney Career Transition

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    Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.

  • Tariffs And FCA Create Perfect Storm For Importers

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    The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.

  • US Reassessment Of OECD Tax Deal Is Right Move

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    The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.

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