International

  • October 23, 2025

    US Oil Cos. Pay More Tax Abroad Than At Home, Report Says

    American oil and gas companies with foreign extraction operations paid more than 80% of their total taxes abroad in recent years despite producing more oil and gas in the U.S. than everywhere else combined, a corporate transparency group said Thursday.

  • October 23, 2025

    IRS To Float Sourcing Rules For Certain Securities Loans

    The Internal Revenue Service said Thursday it intends to propose regulations that would have it look to the borrower of certain securities, rather than the lender, when determining whether related payments are sourced from the United States.

  • October 23, 2025

    Law Firms Could Face £1.4B Bill Under Rumored Tax Change

    Partners at law firms face paying up to £1.4 billion ($1.9 billion) more in tax each year if the government imposes a new tax on limited liability partnerships to help plug a hole in Britain's finances, UHY Hacker Young said Thursday.

  • October 23, 2025

    UK Court Denies Leisure Firm's Bid For Extra VAT Interest

    A leisure services company can't claim additional interest of £8.2 million ($11 million) on value-added tax overpaid to HM Revenue & Customs because statutory interest provided full compensation, a British court ruled.

  • October 23, 2025

    Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion

    Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.

  • October 23, 2025

    Ex-Clifford Chance Pro Hit With £8M Libel Claim By Barrister

    A barrister has sued legal commentator Dan Neidle and his think tank for £8 million ($10.6 million), accusing the former Clifford Chance partner of engaging in a vendetta against him, according to court filings that have now been made public.

  • 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.

Expert Analysis

  • Law Firm Executive Orders Create A Legal Ethics Minefield

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    Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.

  • Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike

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    The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.

  • Firms Must Embrace Alternative Billing Models Or Fall Behind

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    As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.

  • How Attorneys Can Master The Art Of On-Camera Presence

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    As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.

  • Firms Still Have Lateral Market Advantage, But Risks Persist

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    Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • We Must Allow Judges To Use Their Independent Judgment

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    As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.

  • Preparing For Tariffs On Canadian Power In The Northeast

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    The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.

  • Making The Case For Rest In The Legal Profession

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    For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.

  • Mitigating Tariff Risks For Healthcare In US And Canada

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    Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.

  • 4 Ways Women Attorneys Can Build A Legal Legacy

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    This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.

  • A Judge's Pointers For Adding Spice To Dry Legal Writing

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    U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.

  • 7 Tips For Associates To Thrive In Hybrid Work Environments

    Excerpt from Practical Guidance
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    As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.

  • IRS Should Revise Overbroad Microcaptive Regs

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    Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.

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