International

  • July 22, 2025

    UK Releases Proposed Changes To 15% Min. Tax Legislation

    The U.K. released draft legislation aimed at recalibrating its laws on the 15% global minimum tax in a number of ways, including capturing more permanent establishments, excluding more deferred tax assets and adjusting intragroup accounting discrepancies.

  • July 22, 2025

    Irish Board Affirms Tax Bill Against Loss Scheme Participant

    The Irish Tax Appeals Commission closed out one of the remaining cases stemming from an investment fund, citing a court decision that found the participants used the syndicate to generate losses to reduce their taxable income.

  • July 22, 2025

    UK Anti-Tax Avoidance Rules Inconsistent, HMRC Told

    The British government should seek to simplify its anti-tax avoidance rules for income tax to eliminate inconsistencies and avoid double taxation of earnings, accounting firms and tax professionals told HM Revenue & Customs in a consultation.

  • July 22, 2025

    Golf Adviser Reaped $2M In Secret Commissions, Court Rules

    A former consultant to a U.K. golf retailer engaged in deceit, breach of trust and breach of fiduciary duty to reap over $2 million in secret commissions related to sales of golf equipment, a London court ruled Tuesday.

  • July 22, 2025

    OECD Updates Transfer Pricing Profiles For 12 Countries

    The OECD updated 12 countries' entries in its transfer pricing database Tuesday, showing that while none of these countries has adopted the simplified approach for addressing baseline marketing and distribution activities known as Amount B, many have reached a political agreement on the measure.

  • July 22, 2025

    US Expatriations Over 1,000 Again In 2nd Quarter

    While about 200 fewer people expatriated from the U.S. in the second quarter of 2025 compared with the first quarter, the number still totaled above 1,000, the Internal Revenue Service said Tuesday.

  • July 22, 2025

    Gov't Sets Out Plan To Include Pensions In Inheritance Tax

    The government has confirmed that it is pushing ahead with plans to apply inheritance tax to wealth transferred through pensions in a move that experts say marks a "seismic" change for the sector.

  • July 21, 2025

    Guinea Tells DC Circ. $22M Award Can't Be Enforced

    The Republic of Guinea has urged the D.C. Circuit not to revive a consulting company's bid to enforce a $22 million arbitration award, saying a lower court correctly found that it was unclear whether the country agreed to arbitrate the dispute in the first place.

  • July 21, 2025

    Tax-Lien Biz Atty Tells Jury He Didn't Seek To Dupe Lender

    Counsel for a former compliance lawyer accused of pilfering from a $20 million line of credit extended to his tax-lien investment firm told a Manhattan federal jury Monday that the defendant was "sloppy," but never intended fraud.

  • July 21, 2025

    Rising Star: Davis Polk's Aliza Slansky

    Aliza Slansky of Davis Polk & Wardwell LLP is lead counsel in Sycamore Partners' $23 billion acquisition of Walgreens Boots Alliance and advised Missouri tech company Emerson on a series of multibillion-dollar sales, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 21, 2025

    UK Co. Faces £1M Penalty For Failing To Report Tax Scheme

    HM Revenue & Customs was right to determine that a company had promoted a contractor loan tax scheme, a London tribunal ruled, finding the Manchester-based business liable for up to £1 million ($1.3 million) in penalties.

  • July 21, 2025

    Strict Construction Rules Could Gut Solar, Wind Credits

    The U.S. Treasury Department could severely weaken the availability of the solar and wind energy tax credits that were scaled back under Republicans' new budget law with upcoming guidance that may upend long-standing construction rules used to determine eligibility.

  • July 21, 2025

    Family Claims Bad Tax Advice Led To Costly HMRC Bills

    The trustees of family trusts accused a U.K. accounting firm of giving them negligent advice that led to unexpected inheritance taxes and penalties owed to HM Revenue & Customs, according to a claim filed in a London court.

  • July 21, 2025

    UK Launches Online Service Available For 35M Taxpayers

    HM Revenue & Customs launched an online Pay As You Earn portal Monday, available to 35 million U.K. taxpayers, that the British revenue agency said is intended to make it easier to check on tax information as part of HMRC's overall digital transformation.

  • July 21, 2025

    Paul Hastings Boosts Tax Team In NY With Ex-Kirkland Atty

    Paul Hastings LLP announced Monday that a former Kirkland & Ellis LLP attorney is bringing her tax practice to its New York office in a move the firm says will bolster its ability to guide clients through complex deals like mergers, acquisitions and private equity transactions.

  • July 18, 2025

    Law360 Names 2025's Top Attorneys Under 40

    Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age.

  • July 18, 2025

    Trade Legal Matters To Watch: Midyear Report

    Aggressive, sweeping tariff actions have defined the first six months of President Donald Trump's second term, altering the global trade environment in attempts to return manufacturing to the U.S. and reset trading deficits, but legal challenges to certain duties may obstruct Trump's long-term trade strategy in ongoing negotiations later this year.

  • July 18, 2025

    HMRC Urged To Broaden Reporting Of Uncertain Tax Positions

    HM Revenue & Customs may need to change its rules for when taxpayers must disclose uncertain tax positions they've taken to the tax authority, according to a report by a nonprofit research organization.

  • July 18, 2025

    IRS Offers Guidance On Use Of Transfer Pricing Exception

    Taxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday.

  • July 18, 2025

    Trump Asks Supreme Court To Decline Early Tariff Challenge

    President Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts.

  • July 18, 2025

    Western Union Says IRS Used Flawed Rule To Hike Income

    The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.

  • July 18, 2025

    Taxation With Representation: Wachtell, Slaughter And May

    In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.

  • July 18, 2025

    European Tax Policy To Watch In 2nd Half Of 2025

    The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months.

  • July 18, 2025

    EU To Make Foreign Traders Liable For VAT On Imports

    Foreign companies, rather than consumers, will become liable for value-added tax on imports to the European Union beginning July 2028 under a directive adopted Friday by the bloc's council of member states, according to a news release.

  • July 18, 2025

    Oman, Trinidad And Tobago 'Largely Compliant,' OECD Says

    Reviews of the implementation of tax transparency measures in Oman and in Trinidad and Tobago found both nations "largely compliant" with Organization for Economic Cooperation and Development standards, the OECD said Friday.

Expert Analysis

  • 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.

  • Adapting To Private Practice: From NY Fed To BigLaw

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    While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.

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