International

  • February 02, 2026

    US Drops $185K FBAR Case Amid State Dept. Silence

    The U.S. Department of Justice dropped its case Monday accusing a U.S. citizen living in Switzerland of hiding bank accounts from the IRS, telling a D.C. federal court that the U.S. Department of State fell silent on a request for help from Swiss authorities.

  • February 02, 2026

    OECD Amends Tax Treaty Manual To Up Dispute Resolution

    The Organization for Economic Cooperation and Development is updating guidance for tax treaties to strengthen tax treaty mechanisms for preventing cross-border tax disputes, according to a statement Monday.

  • February 02, 2026

    EU Loses €14B In Taxes Annually From US Cos., Report Says

    European Union member states are losing €14 billion ($16.5 billion) in revenues each year as a result of tax avoidance by U.S. companies, Tax Justice Network warned Monday ahead of international tax talks.

  • February 02, 2026

    Norton Rose Grows In Key Cities By Adding 5 Polsinelli Attys

    Norton Rose Fulbright announced Monday that it has added five former Polsinelli PC shareholders as partners to grow its transactional and healthcare capabilities in two key U.S. markets.

  • January 30, 2026

    3 Things To Keep In Mind About IRS' Corporate Audit Changes

    The IRS' revamped audit process for corporate taxpayers will likely streamline examinations, but companies may now shoulder new responsibilities when presenting facts and face lingering uncertainties when weighing whether to participate in a broadened settlement program. Here, Law360 examines three key issues for companies to consider under the new audit process.

  • January 30, 2026

    US Rebukes WTO Siding With China On Energy Tax Credits

    The U.S. Trade Representative condemned the World Trade Organization's decision to side with China in a dispute over energy tax credits passed during former President Joe Biden's term Friday, calling the global body's dispute resolution mechanism inadequate.

  • January 30, 2026

    DOJ Seeks Halliburton's Legal Memo In $35M Tax Fight

    Halliburton has overblown its attorney-client privilege claims over a set of key legal documents the U.S. Department of Justice wants the global oil field operator to disclose as part of the company's $35 million tax refund dispute, the DOJ told a Texas federal court.

  • January 30, 2026

    Taxation With Representation: Clifford Chance, Ropes & Gray

    In this week's Taxation With Representation, real estate investment trust Apollo Commercial Real Estate Finance Inc. announces plans to sell a loan portfolio to retirement services company Athene Holding Ltd., engineering and technology company Leidos acquires Entrust Solutions Group, and Prosperity Bancshares Inc. and Stellar Bancorp Inc. announce a merger.

  • January 30, 2026

    EU Presses 10 Members To Implement Min. Tax Info Rules

    The European Union's executive arm issued warnings Friday to 10 member countries, including Belgium, Cyprus and Sweden, for failing to fully implement the bloc's tax transparency rules for the global minimum tax.

  • January 30, 2026

    EU Calls On 12 Countries To Impose Crypto Tax Rules

    The European Commission is warning 12 countries, including Bulgaria, Czechia and Spain, to extend the European Union's tax transparency rules for crypto-assets, the commission said Friday.

  • January 29, 2026

    Congress' Limited Tariff Role May Persist After Justices Rule

    The U.S. Supreme Court's ruling on President Donald Trump's emergency tariffs could leave the door open for Congress to play a larger role in trade policy heading into November's midterms, but that opportunity may pose few political incentives for lawmakers.

  • January 29, 2026

    8th Circ.'s Ruling For 3M 'Makes No Sense,' Gov't Says

    The Eighth Circuit's ruling that Brazilian law prevented the IRS from reallocating income to 3M from its subsidiary in that country "makes no sense" because the law limits only royalties, not other forms of income, the government argued Thursday in seeking a rehearing by the full court.

  • January 29, 2026

    What Makes A Good Tax Court Expert? Economists Share Tips

    It's not easy being an expert witness in a U.S. Tax Court case. Lawyers ask leading questions and bring up old research; hypothetical scenarios abound, requiring analysis on the fly; and judges have varying levels of expertise, with some seeking detailed explanation and others offended by it.

  • January 29, 2026

    Imported Scooters Not Duty-Free, UK Court Says In Reversal

    Mobility scooters imported into the U.K. by two companies should be assessed a 10% duty, a London court ruled, reversing a lower court decision it said labeled the scooters duty-free due to a misapplication of relevant rules.

  • January 29, 2026

    Fund Managers Should Be Taxed As Workers, HMRC Testifies

    Portfolio managers at BlueCrest Capital Management should be taxed as disguised employees because they don't hold wider legal responsibilities at the hedge fund, Britain's tax authority told the U.K. Supreme Court on Thursday.

  • January 29, 2026

    Australia Issues Tax Reporting Rules For Large Private Cos.

    The Australian Taxation Office issued guidance Thursday for large, privately owned entities to report if they qualify for certain stringent tax integrity measures as well as possible higher penalties.

  • January 29, 2026

    SocGen Loses Case Against French Electric Grid Fees

    A European Union court upheld fees that French companies must pay to access the country's electric grid, ruling against banking giant Société Générale in holding that the payments don't amount to indirect excise taxes that would flout EU law.

  • January 29, 2026

    Microsemi To Report $144M In Overseas Sales In Settlement

    Semiconductor manufacturer Microsemi has agreed to report $144 million in income from sales to its Irish affiliate but will avoid some tax penalties under the terms of a transfer pricing settlement with the Internal Revenue Service, according to a filing in the U.S. Tax Court.

  • January 29, 2026

    5 Indicted In €20M VAT Fraud Involving 'Designer Fuels'

    The European Public Prosecutor's Office indicted five people in Luxembourg suspected of committing €20 million ($23.9 million) in value-added tax fraud through a criminal scheme that traded in what are known as designer fuels, it said Thursday.

  • January 28, 2026

    Tax Court Rejects Aventis' Securitizing Debt Assets

    Pharmaceutical giant Aventis Inc. is ineligible for a favorable tax treatment on its securitization of financial assets, the U.S. Tax Court ruled Wednesday, finding the company did not comply with statutory requirements and failed to show it was not the beneficial owner of the assets.

  • January 28, 2026

    Fund Managers Should Be Taxed As Partners, UK Court Told

    Portfolio managers at a hedge fund should be taxed as partners, not disguised employees, because they have significant influence at the partnership, a hedge fund told the U.K. Supreme Court on Wednesday.

  • January 28, 2026

    Tax Group Of The Year: Skadden

    Skadden Arps Slate Meagher & Flom LLP's tax practice guided several major cases and deals this past year, including representing drugmaker Amgen Inc. in one of the largest transfer pricing cases litigated last year, earning the firm a spot among the 2025 Law360 Tax Groups of the Year.

  • January 28, 2026

    Gov't Escapes Bad Faith Sanctions In FBAR Dispute

    A New York federal judge declined Wednesday to sanction the U.S. government in its suit against the estate of a businessman over undisclosed offshore bank accounts, holding that his widow failed to show the government acted in bad faith.

  • January 28, 2026

    Denmark Looking To Cut Food Taxation By $961M With Deal

    The Danish government and its various political parties have agreed to work on a plan to cut 6 billion kroner ($959 million) in value-added taxes on food annually starting in 2028, its finance ministry said Wednesday.

  • February 04, 2026

    Ropes & Gray Adds 10-Lawyer Linklaters Team In Paris

    Ropes & Gray LLP has recruited a team of 10 lawyers from Linklaters LLP for its new office in Paris as it seeks to boost its services to clients in private funds and tax matters in Europe and worldwide.

Expert Analysis

  • In-House Counsel Pointers For Preserving Atty-Client Privilege

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    Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.

  • Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example

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    Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.

  • Accountant-Owned Law Firms Could Blur Ethical Lines

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    KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.

  • AI Will Soon Transform The E-Discovery Industrial Complex

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    Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.

  • Unpacking The Legal Foundation Of Trump's New Trade War

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    President Donald Trump's recent executive orders and proclamations regarding emergencies at the U.S. border are based on statutory powers enabling a president to address extraordinary external threats — and could be used to fend off legal challenges to the tariffs levied on Mexican and Canadian goods, says Chris Zona at Mandelbaum Barrett.

  • When Innovation Overwhelms The Rule Of Law

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    In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.

  • Imagine The Possibilities Of Openly Autistic Lawyering

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    Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.

  • Litigation Funding Disclosure Debate: Strategy Considerations

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    In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.

  • 5 Ways To Create Effective Mock Assignments For Associates

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    In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.

  • Mentorship Resolutions For The New Year

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    Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.

  • Tax Directive Marks Milestone In Harmonizing EU System

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    The Council of the European Union’s recently adopted tax directive is a significant step toward streamlining and modernizing procedures for member states, and will greatly reduce administrative burden and compliance costs for cross-border investors, says Martin Phelan at Simmons & Simmons.

  • 5 Litigation Funding Trends To Note In 2025

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    Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.

  • Rethinking Litigation Risk And What It Really Means To Win

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    Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.

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