International

  • March 24, 2025

    Caribbean Bank, CEO Accused Of Helping In £415M VAT Fraud

    A Caribbean bank and its former CEO "knowingly" assisted in the commission of a £415 million ($536 million) value-added tax fraud, the creditors of a company allegedly linked to the scam said on the first day of a London trial Monday.

  • March 24, 2025

    TV Star Banned As Co. Director Over Failure To Pay £1M Tax

    A U.K. reality television star has been banned as the director of his media company after it failed to pay more than £1 million ($1.3 million) in taxes, the government's insolvency agency said Monday.

  • March 24, 2025

    FinCEN Exempts US Businesses From Disclosure Rules

    The U.S. Department of the Treasury's financial crimes unit issued interim final rules that exempt domestic businesses from contested reporting regulations, which the department had previously signaled it would narrow to include only foreign companies registered stateside.

  • March 24, 2025

    UK Gov't Considers DST Changes To Prevent US Tariffs

    The Labour government may be considering changes to the digital services tax as part of talks with the U.S. administration to prevent tariffs being imposed on Britain, Chancellor of the Exchequer Rachel Reeves suggested in a TV interview.

  • March 21, 2025

    Court Sours On Tribunal's Sweets Ruling For Marshmallows

    The First-tier Tribunal applied a faulty interpretation of value-added tax law to rule that jumbo-size marshmallows are exempt from VAT, a U.K. Court of Appeal panel said Friday, remanding the £473,000 ($611,000) dispute back to the tribunal.

  • March 21, 2025

    Ex-UBS North America CEO Agrees To $4.9M FBAR Judgment

    The former North American CEO for Swiss bank UBS on Friday agreed to a $4.9 million judgment to end claims that he failed to file timely or accurate foreign bank account reports with the Internal Revenue Service between 2003 and 2013.

  • March 21, 2025

    US-Swiss Agreement Exempts Retirees' Dividends, IRS Says

    U.S. retirement accounts, including trusts, qualified annuity plans and other schemes, are exempt from Swiss taxes on dividends from Swiss companies in which they don't own a controlling interest, according to a U.S.-Switzerland competent authority agreement released Friday by the IRS.

  • March 21, 2025

    Taxation With Representation: Cravath, Paul Weiss, Cooley

    In this week's Taxation With Representation, Google acquires Wiz, QXO Inc. acquires Beacon Roofing Supply, and the Boston Celtics are bought by a group led by private equity firm co-founder William Chisholm.

  • March 21, 2025

    Informal Money Transfers Launder £2B Annually, HMRC Warns

    Criminals in the U.K. are laundering an estimated £2 billion (£2.6 billion) every year via informal money transfer services, HM Revenue and Customs has warned.

  • March 21, 2025

    Spanish Lottery Co. Accused Of Tax Insurance Market Breach

    Spain's competition authority said Friday it is investigating a lottery company on suspicion of suppressing the marketing of tax insurance coverage for lottery winners.

  • March 20, 2025

    Corp. Taxes Should Match Climate Goals, OECD Paper Says

    Countries that want to reduce carbon emissions should design corporate income taxes that align with climate policy objectives, including providing incentives for clean energy investments, according to an OECD working paper released Thursday.

  • March 20, 2025

    Frost Brown Adds Former Houston City Atty To Finance Team

    Frost Brown Todd LLP announced that it has hired an attorney from the ranks of Houston's city government to strengthen its public finance group, adding his expertise in state and local government operations, taxation and economic development.

  • March 20, 2025

    PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.

    Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified.  

  • March 20, 2025

    90% Of Crypto Sellers Conceal Income, Danish Data Shows

    Danish Tax Agency data shows more than 90% of cryptocurrency sellers don't report that income and that many have shifted to foreign platforms to avoid domestic reporting rules, the EU Tax Observatory said in a working paper, suggesting international coordination is essential to tax crypto effectively.

  • March 20, 2025

    Prudential's £9.3M Fees To Silverfleet Taxable, HMRC Argues

    Prudential's payments of £9.3 million ($12 million) to an investment firm are taxable even though the fees were for services the firm carried out when the two companies were part of the same group, the tax authority's counsel told the U.K. Supreme Court on Thursday.

  • March 19, 2025

    IRS Hunter Biden Whistleblower Named Deputy Criminal Chief

    An Internal Revenue Service special agent who accused the U.S. Department of Justice of mishandling an investigation into former President Joe Biden's son has been named deputy chief in the IRS Criminal Investigation division, the agency said Wednesday.

  • March 19, 2025

    Coke's $2.7B Tax Bill Arbitrary, Business Groups Tell 11th Circ.

    Three industry groups asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming that the Internal Revenue Service could raise Coca-Cola's taxes by $2.7 billion, saying in friend-of-the-court briefs that the IRS acted arbitrarily in hiking the Atlanta-based beverage giant's tax liability.

  • March 19, 2025

    Sweden Proposes Cutting Some Green Energy Tax Breaks

    Sweden's Ministry of Finance is proposing that the government slash a pair of green energy tax benefits, one for the installation of solar panels and the other related to the microproduction of renewable energy.

  • March 19, 2025

    Technical, Policy Questions Still Swirl Around Amount B

    U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.

  • March 19, 2025

    DC Judge Won't Preemptively Stop IRS Data Sharing With DHS

    A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their bid for a court order that would preemptively block any information transfer.

  • March 19, 2025

    Switzerland, Zimbabwe Sign Tax Treaty

    Switzerland and Zimbabwe signed an agreement Wednesday for a treaty to avoid double taxation of income, an expansion of the Swiss treaty network in southern Africa that has been welcomed by cantons and businesses, according to Switzerland's competent authority.

  • March 19, 2025

    Law360 Announces The Members Of Its 2025 Editorial Boards

    Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.

  • March 19, 2025

    Group Status Prohibits VAT, Prudential Tells UK Top Court

    Prudential disputed a value-added tax claim on £9.3 million ($12.1 million) in performance fees at the U.K. Supreme Court on Wednesday on the grounds that the business providing the services was a part of the same group as Prudential for tax purposes. 

  • March 19, 2025

    Ex-Glencore Exec Fights £150M Tax On Offshore Shares

    Glencore's former head of oil urged an appeals court Wednesday to overturn a finding he was liable for income tax on nearly £150 million ($194 million) in share distributions from the Jersey company, in a case that could have wide implications on U.K. shareholders of offshore businesses.

  • March 19, 2025

    Disclosure Woes Sink £13M Fraud Trial Against Film Execs

    Prosecutors have abandoned a decade-long fraud case in which four former managers at a film production company were accused of cheating taxpayers out of £13 million ($17 million) because of insurmountable disclosure failures that sunk the case mid-trial.

Expert Analysis

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.

  • Litigation Inspiration: A Source Of Untapped Fulfillment

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    As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

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