International

  • March 13, 2026

    Taxation With Representation: Paul Hastings, Duane Morris

    In this week's Taxation With Representation, uniform maker Cintas Corp. acquires workwear company UniFirst Corp., Controlled Thermal Resources Holdings Inc. plans to go public by merging with a special purpose acquisition company, and a Shell USA Inc. subsidiary sells Jiffy Lube International Inc. to Monomoy Capital Partners.

  • March 13, 2026

    OECD Business Group Calls For Further Pillar 2 Planning

    The OECD's business stakeholder group on Friday called for "continued refinement" of Pillar Two readiness plans to ensure a smooth application of the 15% global minimum tax on corporate profits. 

  • March 12, 2026

    Tariff Refund System Taking Shape, US Customs Tells CIT

    U.S. Customs and Border Protection is making progress developing a system for importers to claim refunds for the global tariff regime struck down by the U.S. Supreme Court, an official told the U.S. Court of International Trade on Thursday.

  • March 12, 2026

    Microsoft, Michigan Settle Cost-Share Receipts Tax Fight

    Microsoft and Michigan reached a settlement over the company's challenge to the state's tax treatment of its cost-sharing agreement receipts with foreign affiliates, according to a dismissal order entered Thursday by the state's Tax Tribunal.

  • March 12, 2026

    IRS Allows 15% Of KFC Parent's Domestic Production Claim

    The IRS and the parent of Pizza Hut, KFC and Taco Bell agreed that the company's total deductions for domestic production activities during 2013-2015 were $1.6 million — roughly 15% of the $10.7 million the company had claimed as deductions for the three years.

  • March 12, 2026

    Reeves Says Energy Windfall Tax May Not Apply By Late 2027

    The U.K.'s energy profits levy is expected to no longer apply to oil and gas operations in the North Sea in the last quarter of 2027, especially if the current Middle East crisis de-escalates and energy prices stabilize, Chancellor of the Exchequer Rachel Reeves told an H&M Treasury committee.

  • March 12, 2026

    Alleged IRS Errors Don't Merit Injunction, Judge Advises

    A Puerto Rico magistrate judge recommended denying a taxpayer's bid to block the IRS from assessing her tax liabilities while the agency's clerical errors that she alleges remain unresolved, holding that she faces uncertainties that don't rise to the level of irreparable harm.

  • March 12, 2026

    EU Top Court Allows Spain's Entertainment VAT Break Limit

    Spain's restriction on VAT deductions linked to entertainment expenses doesn't constitute a violation of European Union law, the bloc's top court said Thursday, rejecting a human resources firm's claim that the country was illegally blocking refunds on business costs.

  • March 11, 2026

    Costco Owes Shoppers Refunds For Voided Tariffs, Suit Says

    Costco shoppers are owed back the higher costs they paid as a result of President Donald Trump's global tariffs that the nation's highest court has since declared unlawful, according to a putative consumer class action filed Wednesday in Illinois federal court.

  • March 11, 2026

    Varian Case Backs $315M Siemens Deduction, Tax Court Told

    The U.S. Tax Court should restore $315 million of Siemens' foreign-dividend tax deduction for the same reasons it upheld a similar deduction for Varian Medical Solutions in 2024, an attorney for Siemens told the court Wednesday.

  • March 11, 2026

    Cos. Ask Court To Toss Trump's Revamped Global Tariffs

    Two companies are challenging President Donald Trump's revamped global tariff regime, telling the U.S. Court of International Trade that the circumstances required to justify the regime cannot exist.

  • March 11, 2026

    Dairy Giant Loses Bid For UK Tax Deductions On IP Transfers

    A London court on Wednesday dismissed a European dairy giant's appeal seeking corporate tax deductions for intellectual property transferred to the partnership by its corporate members.

  • March 11, 2026

    EU Refers Spain To Top Court For Inaction On VAT Directives

    Spain will be referred to the European Union's top court for failing to incorporate two legal directives on value-added tax into Spanish law by a December 2024 deadline, the EU's executive arm said Wednesday.

  • March 11, 2026

    Transfer Pricing Cases Collected £3.4B Last Year, HMRC Says

    The U.K. brought in £3.4 billion ($4.6 billion) in additional revenue from transfer pricing cases from 2024-2025, nearly double the amount from the previous year, according to HM Revenue & Customs data released Wednesday.

  • March 11, 2026

    Barrister's Libel Claim Against Neidle Dismissed As SLAPP

    A judge has struck out a barrister's £8 million ($11 million) libel claim against Dan Neidle, ruling on Wednesday that the case had no chance of succeeding and amounted to a strategic legal claim designed to silence the legal blogger. 

  • March 10, 2026

    Hewlett Packard To Fight IRS Transfer Pricing Adjustments

    Hewlett Packard Enterprise Co. disagrees with transfer pricing adjustments by the IRS and will challenge the agency's efforts to increase its taxable income, the company said in a quarterly report released Tuesday.

  • March 10, 2026

    Exxon Wins $27M Deduction In Canadian Tax Dispute

    The Tax Court of Canada backed Exxon Mobil's bid for a CA$36.2 million ($26.7 million) income deduction for expenses tied to an abandoned Alaskan pipeline project, holding that the company incurred the costs while conducting legitimate business operations.

  • March 10, 2026

    PE Group Asks 3rd Circ. To Overturn Fund's $100M Tax Bill

    The U.S. economy could face damaging consequences if the Third Circuit upholds a U.S. Tax Court decision finding a Cayman Islands hedge fund liable for a $100 million tax bill as a securities dealer, a private equity lobbying group told the court.

  • March 10, 2026

    French Tax Take Outpaces Economic Growth

    France's net tax revenue reached €610 billion ($710 billion) in fiscal year 2025, growing three times faster than GDP, the French tax authority said Tuesday.

  • March 10, 2026

    Portugal Warns Of Carbon Tax Abuse If Exemptions Granted

    A more lenient application of the European Union's carbon leakage tax in the bloc's outermost regions would risk tax evasion, Portugal's finance minister said during a meeting to discuss the bloc's economic agenda.

  • March 10, 2026

    Medtronic, IRS Pursuing Settlement In Transfer Pricing Case

    Medtronic and the Internal Revenue Service are exploring the possibility of settling their U.S. Tax Court case, the parties said, which would avoid the need for a third trial on the pricing intangibles that the Minnesota-based company licensed to its Puerto Rican affiliate in 2005 and 2006.

  • March 10, 2026

    Alston & Bird Adds Deals Pro From Proskauer To Tax Team

    Alston & Bird LLP announced on Tuesday that it has welcomed a tax attorney from Proskauer Rose LLP, saying that his hire will benefit its transactional team and its private equity clients.

  • March 09, 2026

    Kate Hudson's Activewear Co. Sued For Tariff Refunds

    Fabletics, the activewear company cofounded by actress Kate Hudson, faces a proposed class action from customers who say the company passed the cost of President Donald Trump's illegal 2025 tariffs onto customers and should be forced to refund those overages.

  • March 09, 2026

    2nd Circ. Says COVID Policy Saves Argentine Creditors' Case

    The Second Circuit on Monday revived a $5.5 million contractual dispute against Argentina, ruling that a New York state COVID-19 policy saved some bondholder claims from being time-barred.

  • March 09, 2026

    Mining Co. Weighs Arbitration With Mozambique Tax Authority

    An Irish mining company said Monday it's considering international arbitration for a dispute with the Mozambique Tax Authority over the agency's imposition of higher royalties during negotiations on renewing an investment agreement.

Expert Analysis

  • ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'

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    The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.

  • Can Companies Add Tariffs Back To Earnings Calculations?

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    With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.

  • A Look At DOJ's Dropped Case Against Early Crypto Operator

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    The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.

  • 8 Ways Lawyers Can Protect The Rule Of Law In Their Work

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    Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.

  • Law School's Missed Lessons: Communicating With Clients

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    Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

  • Navigating Antitrust Risks When Responding To Tariffs

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    Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.

  • Key Points From HMRC's Tax Reform Proposals

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    Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • What To Note As UK Adopts OECD Crypto Disclosure Rules

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    With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

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