International

  • February 19, 2026

    Most Of New Hires Won't Handle Mansion Tax, HMRC Says

    Most of the 1,000 tax officials being hired by Britain's tax authority ahead of the rollout of the high-value council tax surcharge known as the mansion tax will not work directly on the tax, the authority's valuation office said Thursday.

  • February 18, 2026

    Varian Contests $1.5B IRS Bill In Tax Court

    Varian Medical Systems does not owe $1.24 billion in additional taxes or $248 million in penalties the IRS assessed after the agency recharacterized the company's sales of subsidiaries in the Netherlands and Switzerland, the company told the U.S. Tax Court.

  • February 18, 2026

    IRS Asks Court To Deny Probe Of Improper ICE Data-Sharing

    A coalition suing the IRS over its data-sharing deal with immigration enforcement authorities should not be allowed to investigate the agency's revelation that it shared some data improperly, the IRS told a D.C. federal court, saying it made the admission "in good faith."

  • February 18, 2026

    Glencore Says It Paid $1B To HMRC Over Tax Disputes

    Mining giant Glencore told shareholders Wednesday that it paid $1 billion to the U.K.'s tax authority last year over tax disputes but is pushing to recover some of the money.

  • February 18, 2026

    Tax Group Of The Year: Eversheds Sutherland

    Eversheds Sutherland's tax practice advised on key deals in 2025, guiding Duke Energy in securing $20 million in investment credits and aiding Verizon in avoiding $12 million in corporate franchise taxes, earning it a spot among the 2025 Law360 Tax Groups of the Year.

  • February 18, 2026

    8th Circ. Misread Law In 3M's $24M Case, Tax Prof Says

    The Eighth Circuit misconstrued the statute underpinning transfer pricing regulations when it blocked the IRS from allocating nearly $24 million of 3M Co.'s Brazilian income, a tax professor said in backing the agency's bid for a rehearing by the full court.

  • February 18, 2026

    Australia Seeks Input On Global Minimum Tax Amendments

    Australia is looking for input on changes to its global minimum tax legislation aimed at implementing Organization for Economic Cooperation and Development guidance, including tweaks to how its domestic minimum tax applies to stateless entities and joint ventures, the Department of the Treasury said.

  • February 17, 2026

    No Fraud By IRS In FOIA Over $18M Tax Case, DC Circ. Says

    The Internal Revenue Service did not commit fraud when it said records were missing amid Freedom of Information Act litigation related to an $18 million tax case, the D.C. Circuit said Tuesday, denying claims made by the estate of a man whose offshore businesses were raided.

  • February 17, 2026

    Ex-IRS Official Drops Suit Over Private Info Leak

    The former commissioner of the IRS' Large Business and International Division asked a D.C. federal court to drop her suit accusing the agency of unlawfully leaking information on her employment status to the media, according to a filing.

  • February 17, 2026

    UK Court Blocks Telecom's £51M VAT Refund Bid

    A London appeals court dismissed a U.K. telecommunications provider's bid to recover £51.1 million ($69.3 million) in value-added tax payments, agreeing with a lower court's conclusion that VAT is owed when phone plans are sold, not when they're used.

  • February 17, 2026

    OECD Updates Tool For Amount B And Issues Guidance

    The Organization for Economic Cooperation and Development released an updated tool Tuesday for making calculations under its transfer pricing method known as Amount B and issued guidance on frequently asked questions.

  • February 17, 2026

    EU Seeks Feedback For Bill To Streamline Corporate Tax Laws

    The European Union is seeking feedback on how to streamline its corporate tax laws in a bill slated to be proposed in the second quarter of the year, the bloc's executive branch said.

  • February 17, 2026

    Ireland Looks At Expanding Coverage Of R&D Tax Credit

    Ireland is looking at expanding the coverage of its research and development tax credit, including by revising qualifying expenditures, subcontracting rules and capital expenditures, according to a report by the country's finance ministry.

  • February 17, 2026

    Unregistered Tax Advisers May Be Blocked, HMRC Warns

    HM Revenue & Customs may block intermediaries who fail to register as a tax adviser, including for corporate and personal tax matters, cutting them off from services, the tax authority said Tuesday.

  • February 17, 2026

    Sweden Proposes New Tools To Combat VAT Fraud

    Swedish lawmakers are mulling legislation that would target value-added tax fraud through a series of new measures, including enabling tax officials to deny VAT registration if they see red flags, Sweden's Finance Ministry announced Tuesday.

  • February 17, 2026

    EU Blacklists Turks and Caicos, Vietnam As Tax Havens

    The European Union blacklisted two countries as tax havens Tuesday over their failure to meet transparency standards and policies encouraging foreign companies and entities to shift their profits overseas.

  • February 13, 2026

    Senate Dems Say IRS-ICE Privacy Warnings Proved Correct

    The Internal Revenue Service's recent admission that a faulty system improperly shared taxpayer records with U.S. Immigration and Customs Enforcement vindicates long-standing warnings about privacy and data protection risks, Senate Democrats said.

  • February 13, 2026

    Gov'ts To Explore Transfer Pricing Database For UN Tax Pact

    Governments are expected to form a task force on improving access to transfer pricing information, including by potentially creating a database, to support the dispute protocol under the United Nations framework convention on international tax cooperation, according to negotiations on the protocol held Friday.

  • February 13, 2026

    FinCEN Eases Beneficial Owner ID Rules For Banks

    The U.S. Treasury Department's Financial Crimes Enforcement Network announced Friday that banks are excepted from certain aspects of the agency's customer due diligence rules, including the requirement to repeatedly identify the beneficial owners of existing corporate account holders.

  • February 13, 2026

    Fuel Credit Regs Clear Clouds Over Middleman Sales

    The U.S. Treasury Department's move to allow domestic clean fuel producers selling to intermediaries to qualify for the production tax credit under newly released proposed rules recognizes the industry's commercial realities and clears up uncertainty that had been hindering the market, practitioners said.

  • February 13, 2026

    Taxation With Representation: Homburger, Lenz & Staehelin

    In this week's Taxation With Representation, offshore drilling contractor Transocean Ltd. acquires rival Valaris Ltd., historic British fund manager Schroders agrees to a cash takeover by U.S. asset manager Nuveen, and a consortium that includes U.S. private equity firm Advent International LP and FedEx Corp. buy Polish parcel locker company InPost.

  • February 13, 2026

    Blair's Think Tank Urges UK Gov't To End Energy Windfall Tax

    The U.K.'s Labour government must phase out the windfall tax on the energy industry and lift the ban on new oil and gas drilling licenses in the North Sea to increase revenue long term, the Tony Blair Institute said Friday.

  • February 12, 2026

    IRS Guidance Offers Relief In Energy Credits' Sourcing Limits

    The IRS issued interim guidance Thursday providing two safe harbor options for clean energy facilities or manufacturers of energy components to determine the extent to which they received material assistance from an entity tied to a foreign government that the U.S. deems adversarial.

  • February 12, 2026

    Gov'ts Favor Optionality In UN Tax Treaty's Dispute Protocol

    Governments widely supported having the ability to choose between options for dispute resolution and prevention while making an opt-out unavailable for some methods in the dispute protocol under the United Nations framework convention on international tax cooperation, according to negotiations on the protocol.

  • February 12, 2026

    Canadian Living In Wash. Says FBAR Penalty Required Jury

    A Canadian man living in the U.S. was unconstitutionally fined more than $700,000 for failing to report his foreign bank accounts, he told a Washington federal court, arguing that the amount is excessive and that its assessment violates his right to a jury trial.

Expert Analysis

  • In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable

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    The U.S. District Court for the Eastern District of Virginia was again one of the fastest civil trial courts in the nation last year, and an interview with the court’s newest judge provides insights into why it continues to soar, says Robert Tata at Hunton.

  • How Attorneys Can Become Change Agents For Racial Equity

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    As the administration targets diversity, equity and inclusion efforts and law firms consider pulling back from their programs, lawyers who care about racial equity and justice can employ four strategies to create microspaces of justice, which can then be parlayed into drivers of transformational change, says Susan Sturm at Columbia Law School.

  • Adapting To Private Practice: From US Attorney To BigLaw

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    When I transitioned to private practice after government service — most recently as the U.S. attorney for the Eastern District of Virginia — I learned there are more similarities between the two jobs than many realize, with both disciplines requiring resourcefulness, zealous advocacy and foresight, says Zach Terwilliger at V&E.

  • The Ins And Outs Of Consensual Judicial References

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    As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.

  • The BigLaw Settlements Are About Risk, Not Profit

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    The nine Am Law 100 firms that settled with the Trump administration likely did so because of the personal risk faced by equity partners in today's billion‑dollar national practices, enabled by an ethics rule primed for modernization, says Adam Forest at Scale.

  • Customs Fraud Enforcement In The Age Of Tariffs

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    In the wake of the Trump administration’s new approach toward tariffs, two recent Justice Department developments demonstrate aggressive customs fraud enforcement, with the DOJ emphasizing competitive harm to American businesses, and signaling that investigations will likely involve both civil and criminal enforcement tools, say attorneys at Bernstein Litowitz and London & Naor.

  • Power To The Paralegals: An Untapped Source For Biz Roles

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    Law firms looking to recruit legal business talent should consider turning to paralegals, who practice several key skills every day that prepare them to thrive in marketing and client development roles, says Vanessa Torres at Lowenstein Sandler.

  • How Trucking Cos. Can Keep Rolling Under Tariff Burdens

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    Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.

  • $38M Law Firm Settlement Highlights 'Unworthy Client' Perils

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    A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.

  • Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case

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    A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.

  • Evolving Federal Rules Pose Further Obstacles To NY LLC Act

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    Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.

  • Reassessing Corporate Separateness After Explosion Of LLCs

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    Following the dramatic increase of limited liability companies in the U.S., the Corporate Transparency Act's enactment and the Trump administration's subsequent narrowing of that law, it's worth revisiting the underlying legal principles that govern shell companies in order to remedy the problems that initially motivated the CTA, says Jeff Newton at Omni Bridgeway.

  • Crisis Management Lessons From The Parenting Playbook

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    The parenting skills we use to help our kids through challenges — like rehearsing for stressful situations, modeling confidence and taking time to reset our emotions — can also teach us the fundamentals of leading clients through a corporate crisis, say Deborah Solmor at the Wisconsin Alumni Research Foundation and Cara Peterman at Alston & Bird.

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