International
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March 03, 2026
Fed. Circ. Wrestles With Treaty Language In Tax Credit Fights
A Federal Circuit panel grappled Tuesday with how to interpret a phrase in the U.S. government's tax treaties with Canada and France that allows foreign tax credits subject to limitations in the Internal Revenue Code as it weighed two refund disputes.
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March 03, 2026
DC Circ. Urged To Aid Discovery In ICE-IRS Data-Sharing Case
A taxpayer group challenging the legality of a deal allowing the Internal Revenue Service to share taxpayer location information with immigration authorities asked the D.C. Circuit to remand part of the case to investigate the IRS' admission that it improperly shared addresses under the agreement.
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March 03, 2026
UK Tribunal Blocks Firm From Reviving Wage Subsidy Claim
A flooring company cannot challenge a lower court's ruling that HM Revenue & Customs correctly used a lower salary figure than provided to determine payments under a wage subsidy scheme during the COVID-19 pandemic, the Upper Tribunal said in a decision released Tuesday.
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March 03, 2026
Gov't Goes After $19M In Biofuel Tax Credit Fraud Case
A businessman who owes more than $19 million to a company subject to forfeiture over its involvement in a $511 million biofuel tax credit fraud must hand over the money to the federal government now that a catfishing scheme targeting him is resolved, the government told a Utah federal court.
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March 03, 2026
Reeves Says UK Will Stick With Higher Tax Take Strategy
Chancellor of the Exchequer Rachel Reeves said Tuesday that the U.K. government will keep its plans to meet its fiscal rules by increasing its tax take despite calls for tax cuts from businesses and concerns over financial stability.
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March 03, 2026
EU Energy Groups Seek Extension Of VAT Fraud Fighting Tool
Energy associations urged European Union lawmakers Tuesday to extend a tool used to fight value-added tax fraud that is set to expire in December, saying an extension will ensure the proper functioning of carbon emissions markets and energy certificate trading.
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March 02, 2026
Fed. Circ. Quickly Releases Mandate In Trump Tariff Case
Businesses and states that successfully challenged President Donald Trump's global tariff regime can proceed with their efforts to seek refunds, as the Federal Circuit expedited the release of its mandate in the case to the U.S. Court of International Trade on Monday.
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March 02, 2026
Disregarded Entity Can't Claim Basis In Partnership
A company that elected to be treated as a disregarded entity — a branch of its parent — and attempted to pay for interest in a partnership with a promissory note from the parent can't claim a basis in the partnership for 2009, the U.S. Tax Court held Monday.
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March 02, 2026
FedEx Customers Seek Refunds For Passed-On Tariff Costs
A proposed class action in Florida federal court looks to make sure FedEx refunds customers for the costs of tariffs the shipping giant passed on to them as the company looks to recoup its payments made under President Donald Trump's illegal tariff regime.
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March 02, 2026
Int'l Tax In February: Check On US Tariffs Prompts Reactions
Over the past month, new U.S. Internal Revenue Service rules on clean fuel and energy tax credits have brought certainty for some taxpayers, even as the end of tariffs imposed under the U.S. International Emergency Economic Powers Act has created new uncertainty around recent trade deals with India and the European Union. Here, Law360 looks at the biggest international tax developments in February.
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March 02, 2026
China Seeking To Stop Illegal Tax Breaks By Local Gov'ts
China has been clamping down on illegal efforts by local governments to attract investment by providing tax breaks to taxpayers who reside or operate outside their jurisdictions, the country's State Taxation Administration said Monday.
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March 02, 2026
HMRC Bags Extra £16B From Big Businesses, Audit Says
HM Revenue & Customs collected almost £16 billion ($21.3 billion) in extra tax revenue from the biggest businesses in fiscal year 2024-25 after it took a stricter approach to compliance, the National Audit Office found.
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March 02, 2026
Guernsey Weighs Wider Access To Beneficial Ownership Info
Guernsey is considering allowing people who can demonstrate a "legitimate interest," such as journalists, nongovernmental organizations and due diligence service providers, to access beneficial ownership information about companies in its jurisdiction, according to the government.
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March 02, 2026
Australian Tax Debt Relief Flagged As Inconsistent
The Australian Taxation Office has been inconsistent about when it reduces interest charges on tax debts for individuals and small businesses, leading to "confusion and unfair outcomes," according to a report Monday by the country's tax watchdog.
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March 02, 2026
Spanish Official To Lead OECD Tax Transparency Forum
A Spanish tax official has been appointed to lead the secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, the Organization for Economic Cooperation and Development said.
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March 02, 2026
Customs, VAT Fraud Costing €45B, EU Prosecutors Say
Cross-border customs and value-added tax fraud are reshaping the criminal landscape in the European Union, with such schemes generating an estimated €45 billion ($52.7 billion) in damage, according to a report published Monday by an independent prosecuting body.
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February 27, 2026
Older UK Homeowners Tap £6.2B Home Equity To Cut Tax Bills
A growing number of people in the U.K. over age 66 are turning to equity release to reduce their inheritance tax liability, with £6.2 billion ($8.4 billion) in mortgage releases in 2024-25, according to financial data revealed Saturday.
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February 28, 2026
2nd Circuit Says IRS Can Apply Foreign Biz Reporting Penalty
The Internal Revenue Service may use administrative assessment to collect penalties from a taxpayer for failing to report control of a foreign business from 2005 to 2009, the Second Circuit held Friday, vacating a U.S. Tax Court ruling.
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February 27, 2026
Trump's Trade Deals Face Tricky Path After Tariff Ruling
While President Donald Trump has said the trade agreements struck in response to tariffs that have now been invalidated by the U.S. Supreme Court will be kept, navigating the terms of those deals in the aftermath is already proving complicated.
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February 27, 2026
Denmark's Top Party Plans Wealth Tax Ahead Of Elections
Denmark's top party has proposed a 0.5% wealth tax as a pillar of its platform for early elections called by a prime minister seeking to build on public support for her efforts to prevent the U.S. from taking over Greenland.
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February 27, 2026
Taxation With Representation: Linklaters, Wilson Sonsini
In this week's Taxation With Representation, French electric utility Engie acquires UK Power Networks, Gilead Sciences Inc. buys clinical-stage biotechnology company Arcellx Inc., and The Brink's Co. acquires NCR Atleos in a deal that unites two major companies in the ATM business.
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February 27, 2026
UK Christian Schools Pledge Top Court Appeal After VAT Loss
A group of Christian families and schools said they will take their appeal against the 20% value-added tax charged on their private school fees to the U.K. Supreme Court after an appeals court dismissed their case Friday.
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February 26, 2026
IRS Broke Law 42K Times By Giving Info To ICE, Judge Says
The federal judge who stopped the Internal Revenue Service from sharing taxpayer addresses with immigration authorities said Thursday that a recent admission by the agency showed that it broke the law more than 42,000 times last summer when it disclosed addresses by relying on a computerized matching system.
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February 26, 2026
Penalties Apply In 'Missing Witness' Case, Tax Court Says
The U.S. Tax Court won't reconsider its decision that a couple who had argued they were misled by their accountant are liable for penalties over failing to file and failing to pay estimated tax in a case where they neglected to call the accountant as a witness.
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February 26, 2026
Biz Owner Gets £2M Tax Evasion Penalty Tossed As Unfair
A company owner isn't liable for a nearly £2 million ($2.7 million) civil tax evasion penalty because HM Revenue & Customs didn't raise its claims of dishonesty by the owner in a prior proceeding it relied on later, a London court said Thursday.
Expert Analysis
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5 Tariff And Trade Developments To Watch In 2026
A new trade landscape emerged in 2025, the contours of which will be further defined by developments that will merit close attention this year, including a key ruling from the U.S. Supreme Court and a review of the U.S.-Mexico-Canada Agreement, says Ted Posner at Baker Botts.
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4 Developments That Defined The 2025 Ethics Landscape
The legal profession spent 2025 at the edge of its ethical comfort zone as courts, firms and regulators confronted how fast-moving technologies and new business models collide with long-standing professional duties, signaling that the profession is entering a period of sustained disruption that will continue into 2026, says Hilary Gerzhoy at HWG Law.
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How Fractional GCs Can Manage Risks Of Engagement
As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.
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How OECD Tax Update Tackles Mobile Workforce Complexity
The Organization for Economic Cooperation and Development’s recently updated model tax convention — a recalibration of international tax principles in response to an increasingly mobile workforce — should prompt companies to reevaluate cross-border operations, transfer pricing policies and tax controversy strategies, say attorneys at Eversheds.
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A Uniform Federal Rule Would Curb Gen AI Missteps In Court
To address the patchwork of courts’ standing orders on generative artificial intelligence, curbing abuses and relieving the burden on judges, the federal judiciary should consider amending its civil procedure rules to require litigants to certify they’ve reviewed legal filings for accuracy, say attorneys at Shook Hardy.
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Supreme Court Term Limits Would Carry Hidden Risk
While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
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Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave
The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.
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AI Evidence Rule Tweaks Encourage Judicial Guardrails
Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.
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The Law Firm Merger Diaries: Getting The Message Across
Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.
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Horizontal Stare Decisis Should Not Be Casually Discarded
Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.
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10 Commandments For Agentic AI Tools In The Legal Industry
Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.
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The Law Firm Merger Diaries: How To Build On Cultural Fit
Law firm mergers should start with people, then move to strategy: A two-level screening that puts finding a cultural fit at the pinnacle of the process can unearth shared values that are instrumental to deciding to move forward with a combination, says Matthew Madsen at Harrison.
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Rare Tariff Authority May Boost US Battery Manufacturing
Finalizing preliminary tariffs on active anode material from China — the result of a rare exercise of statutory authority finding that foreign dumping hampered the development of a nascent U.S. industry — should help domestic battery manufacturing, but potential price increases could discourage related clean-energy use, say attorneys at MoloLamken.