International

  • 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.

  • November 18, 2025

    Korea Wins Annulment Of $216M Lone Star Funds Award

    South Korea on Tuesday prevailed in its bid to wipe out a $216 million arbitral award issued to an affiliate of Lone Star Funds, though the private equity firm has already vowed to resubmit its claim to a new tribunal.

  • November 18, 2025

    Malawi Reiterates Bid For Gem Export Tax Investigation

    Malawi has bolstered its bid for a Washington federal judge to reconsider his decision barring the country from pursing discovery against a gemstone company that partnered with a mining outfit the country claims dodged billions of dollars in taxes and export royalties.

  • November 18, 2025

    French Inheritance Tax Break Grew To €5.5B, Auditor Finds

    The French government's inheritance tax break for family-owned businesses needs to be overhauled as the cost surged to more than €5.5 billion ($6.4 billion) last year, the state auditor said Tuesday.

  • November 18, 2025

    Tax Return Preparer Gets 18 Months For $25 Million Fraud

    A California tax return preparer who admitted he participated in a scheme that claimed $25 million in false refunds was sentenced to 18 months in prison by a California federal court, the U.S. Department of Justice said.

  • November 18, 2025

    Checklist Could Help Simplify Global Tax Policy, OECD Says

    A checklist of questions for global tax policymakers could help simplify the outcomes of their work, the OECD said in a Tuesday report to the Group of 20 nations.

  • November 17, 2025

    Judge Questions Eaton's Role In Lowered Credit Rating

    Tax Court Judge Albert Lauber questioned an expert for Eaton on Monday about how he arrived at a lowered credit rating for the U.S. company in a report he prepared in January 2013, shortly after it acquired an Irish-based global electrical products manufacturer and inverted.

  • November 17, 2025

    Ex-Russian Gas CFO Resentenced To 6 Years For Tax Crimes

    A Florida federal judge handed a nearly six-year prison term to a Russian gas company's former chief financial officer, who was convicted for tax evasion after the Eleventh Circuit vacated a prior sentence earlier this year.

  • November 17, 2025

    Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free

    A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International Trade's decision in a decade-old dispute.

  • November 17, 2025

    OMB Reviewing Treasury Regs On OECD Crypto Reporting

    The Office of Management and Budget is reviewing regulations proposed by the U.S. Department of the Treasury to implement automatic exchanges of information between tax authorities regarding taxpayers' cryptocurrency holdings under the OECD's crypto-asset reporting framework.

  • November 17, 2025

    MVP: Sullivan & Cromwell's Isaac Wheeler

    Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Tishman Speyer on its $3.5 billion refinancing of Rockefeller Center, earning him a spot as one of the 2025 Law360 Tax MVPs.

  • November 17, 2025

    Fed. Circ. Backs Commerce To Nix Turkish Steel Duties

    The U.S. Department of Commerce's removal of countervailing duties on Turkish steel imports was properly justified by the government, and the lower trade court correctly upheld its determination despite objections by the domestic steel industry, the Federal Circuit affirmed Monday.

Expert Analysis

  • Measuring And Mitigating Harm From Discriminatory Taxes

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    In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.

  • Adapting To Private Practice: From DOJ Leadership To BigLaw

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    The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.

  • How The CRE Industry Is Adapting To Tariff Uncertainty

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    Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.

  • 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.

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