International
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December 22, 2025
Draft House Bill Would Clarify Tax Rules For Digital Assets
A bipartisan draft bill in the U.S. House would modernize the federal tax code for digital assets, its backers said, by establishing a "commonsense tax treatment" for regulated payment stablecoins, clarifying source-of-income rules for trading and extending existing securities-lending rules to digital assets.
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December 22, 2025
Top Federal Tax Policies Of 2025
The first year of President Donald Trump's second term brought the passage of this summer's budget reconciliation bill, which renewed major parts of the 2017 Tax Cuts and Jobs Act, and major staffing changes at the Internal Revenue Service. Here, Law360 looks at the most consequential developments in federal tax policy in 2025.
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December 22, 2025
Tariff Refunds Would Be 'A Mess,' Economic Official Says
It would be an "administrative problem" to issue tariff refunds in the aftermath of a potential U.S. Supreme Court ruling against the White House's trade measures, a top economic policy official said.
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December 22, 2025
IRS Seeks Input On Updates To Voluntary Disclosure Process
The Internal Revenue Service asked Monday for comments on a proposed change to its voluntary disclosure program that would require payment of all taxes, penalties and interest within three months after being conditionally approved for the program.
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December 19, 2025
EU High Court Advised To Force Portugal To Reclaim Taxes
The European Union's top court should rule that Portugal can't allow tax enforcement proceedings to be suspended in the case of unlawful state aid granted by the Madeira Free Zone, an adviser to the court said.
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December 19, 2025
Trade Court Remands Canada Lumber Duty Calculation Again
The U.S. Commerce Department again failed to sufficiently justify how it calculated a subsidy rate in an antidumping duty administrative review for a Canadian exporter of softwood lumber products, the U.S. Court of International Trade said.
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December 19, 2025
Taxation With Representation: Baker Botts, Morgan Lewis
In this week's Taxation With Representation, Trump Media and Technology Group merges with fusion power company TAE Technologies, pharmaceutical company Cencora boosts its stake in cancer care company OneOncology, and Phoenix Financial partners with private equity giant Blackstone to plug billions into various credit strategies.
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December 19, 2025
Calif. Ex-Customs Broker Sentenced For Tax, Wire Fraud
A California man was sentenced to 51 months in federal prison after being indicted this year on federal fraud charges and one count of tax evasion, the U.S. Department of Justice said.
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December 19, 2025
Polsinelli Lands Glaser Weil Tax Pro In Los Angeles
Polsinelli PC is expanding its business team, bringing in a tax pro from Glaser Weil as a shareholder in its Los Angeles office.
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December 18, 2025
Czech Republic, Estonia Shift To Backing Min. Tax Deal For US
The Czech Republic and Estonia have shifted to supporting the proposed U.S. exemption from the global minimum tax's international provisions at the global tax policymaking body hosted by the Organization for Economic Cooperation and Development, the countries' finance ministries told Law360.
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December 18, 2025
Australia Issues Guidance On Min. Tax For Merged Accounts
Australia's tax authority released several guidance documents detailing how the global minimum tax interacts with separate laws on accounting consolidation for corporate groups, as well as issues related to mismatched fiscal years among constituent entities.
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December 18, 2025
Denmark Files To Appeal £1.4B Cum-Ex Fraud Case Defeat
Denmark has launched its effort to revive its £1.4 billion ($1.8 billion) case over a tax fraud allegedly orchestrated by convicted hedge fund trader Sanjay Shah, according to court filings seen by Law360 Thursday.
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December 18, 2025
HMRC Wins Burden Of Proof Query In £54M Tax Fraud Case
A London appeals court ruled Thursday that HM Revenue & Customs doesn't bear the burden of proof in its tax liability claim against a British businessman it alleges used a company to commit alcohol smuggling and tax evasion of over £54 million ($72.2 million), plus penalties.
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December 17, 2025
Court Remands Commerce Ruling On Vietnam Steel Duties
The U.S. Department of Commerce did not properly substantiate its 2023 findings that imports of Vietnamese steel products were flouting duties imposed on South Korea, India and China, the U.S. Court of International Trade said, remanding the agency's determinations.
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December 17, 2025
Ex-Biden Tax Counsel To Chair Willkie Tax Resolution Team
Willkie Farr & Gallagher LLP has hired a former senior tax counsel who worked in two Democratic presidential administrations to come on board as chair of the firm's tax resolution practice group, according to a Wednesday announcement.
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December 17, 2025
EU Looking To Merge Tax Directives Into Single Instrument
The European Commission is considering consolidating the nine bloc directives on administrative taxation cooperation — which cover such areas as the Organization for Economic Cooperation and Development's global minimum tax, crypto-asset reporting and cross-border tax rulings — into one legal instrument.
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December 17, 2025
Treasury Issues Final Rule On BEAT For Securities Lending
Taxpayers must determine and account for certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax, according to a final rule released Wednesday by the U.S. Department of the Treasury.
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December 17, 2025
EU Looks To Expand CBAM To Machinery, Other Products
The European Union has proposed expanding its carbon border adjustment mechanism beyond basic materials to cover certain steel- or aluminum-intensive products like machinery and appliances, saying it wants to prevent spurring emissions-heavy production outside the bloc.
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December 17, 2025
Brazil's New Dividend Tax Rules To Impose 10% Withholding
Dividends and profits paid by Brazilian entities to nonresidents will generally be subject to a 10% withholding tax starting in the new year, the country's revenue agency said in recent guidance, adding that 2025 distributions must be approved before the end of this year to avoid the new tax.
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December 17, 2025
Tax Authorities Shared Data 5,500 Times In 2024, OECD Says
Tax authorities exchanged information on tax rulings 5,500 times last year as part of the base erosion and profit-shifting rules developed by the Organization for Economic Cooperation and Development, according to a report published Wednesday.
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December 17, 2025
UK Supreme Court Tosses Hotel's Atty Fee VAT Appeal
A hotel company can't reclaim value-added tax paid on fees to lawyers and accountants as part of selling a subsidiary to finance the opening of a new hotel, the U.K. Supreme Court ruled Wednesday.
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December 16, 2025
Corporate Transparency Act Is Constitutional, 11th Circ. Says
The Corporate Transparency Act is constitutional because it regulates economic activities with a substantial impact on interstate commerce and doesn't violate protections against unreasonable searches, the Eleventh Circuit said Tuesday, reversing a lower court's decision.
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December 16, 2025
Developing Nations Expand Corporate Tax Breaks, OECD Says
Low- and middle-income countries generally expanded corporate tax incentives in 2024, while some coupled those measures with tax increases, the OECD reported Tuesday.
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December 16, 2025
Fired Top Antitrust Official Warns Of 'Politicization'
The former No. 2 at the U.S. Department of Justice's Antitrust Division until he was terminated this year testified Tuesday about the "politicization" of antitrust enforcement.
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December 17, 2025
CORRECTED: Trade Court Nixes Injunction In Trump Tariff Suit
The U.S. Court of International Trade has denied a preliminary injunction in a suit challenging President Donald Trump's emergency tariffs after auto part retailers failed to convince the court that the relief was necessary to preserve their potential right to refunds.
Expert Analysis
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ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'
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.
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Can Companies Add Tariffs Back To Earnings Calculations?
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.
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A Look At DOJ's Dropped Case Against Early Crypto Operator
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.
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8 Ways Lawyers Can Protect The Rule Of Law In Their Work
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.
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Law School's Missed Lessons: Communicating With Clients
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.
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Navigating Antitrust Risks When Responding To Tariffs
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.
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Key Points From HMRC's Tax Reform Proposals
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.
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Adapting To Private Practice: From US Rep. To Boutique Firm
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.
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IRS Should Work With Industry On Microcaptive Regs
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.
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What To Note As UK Adopts OECD Crypto Disclosure Rules
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.
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Senate's 41% Litigation Finance Tax Would Hurt Legal System
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.
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
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.
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Move Beyond Surface-Level Edits To Master Legal Writing
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.