International
-
February 11, 2026
Denmark Says Cum-Ex Ruling No Bar To £56M Fraud Claim
Denmark told Britain's top court on Wednesday that it should be allowed to sue an English brokerage for £56 million ($76 million) over a tax refund fraud, arguing that an earlier decision barring linked allegations was based on "fundamentally different" facts.
-
February 10, 2026
Gov'ts Want Varied Nexus In UN Treaty's Services Protocol
Business models should have different nexus rules that don't rely on physical presence in the protocol on cross-border services under the United Nations framework convention on international tax cooperation, governments said Tuesday.
-
February 10, 2026
DOJ Drops Bid For Offshore Asset Freeze In $28M Tax Suit
The U.S. Department of Justice and a family of overseas-trust beneficiaries struck a partial deal in a $28 million tax suit in Florida federal court, with the DOJ dropping its push to freeze the family's assets and the family agreeing to temporarily limit their account withdrawals.
-
February 10, 2026
Ex-Clifford Chance Pro Says £8M Libel Claim Is SLAPP
Legal commentator Dan Neidle asked a court on Tuesday to use new powers to throw out an £8 million ($11 million) libel claim accusing the former Clifford Chance partner of engaging in a vendetta against a barrister, arguing that the claim was launched to silence him.
-
February 09, 2026
Gov'ts Back UN Treaty's Services Protocol Covering DSTs
All income taxes and digital services taxes should be covered by the protocol on cross-border services under the United Nations framework convention on international tax cooperation, many governments said Monday during negotiations regarding the protocol.
-
February 09, 2026
DOD Employee Denies Laundering Millions For Scammers
A U.S. Department of Defense logistics specialist pled not guilty Monday to federal charges accusing him of laundering millions as part of an alleged Nigeria-based fraud scheme that targeted victims in the United States.
-
February 09, 2026
$19M In Foreign Account Penalties Required Jury, Court Told
A U.S.-German citizen who failed to report his foreign accounts to the IRS told a Florida federal court that his $19 million punishment violates his right to a jury trial under a U.S. Supreme Court ruling that curbed the use of in-house agency courts to hand down stiff penalties.
-
February 09, 2026
€306M Money Laundering Network Sting Leads To 13 Arrests
Law enforcement agencies in the European Union have arrested more than a dozen people in several raids after an investigation into a €306 million ($364.5 million) international money laundering scheme with links to drug trafficking and tax fraud.
-
February 08, 2026
DOJ Drops Challenge To AbbVie's $1.6B Break Fee Deduction
The U.S. Department of Justice agreed to stop fighting a key U.S. Tax Court ruling that allowed pharmaceutical giant AbbVie to claim a $1.6 billion termination fee to an Irish biotechnology company as an ordinary tax deduction, according to a filing in the Seventh Circuit.
-
February 08, 2026
HMRC Nets £246M In Evasion-Focused Inheritance Tax Probes
Britain's tax authority has recovered an additional £246 million ($336 million) in inheritance tax secured by investigations, according to data released Sunday.
-
February 06, 2026
4 Takeaways From The EU's Latest Trade Agreements
The European Union recently cemented formal trade agreements with India and Mercosur, a group of Latin American countries, which — along with creating certainty for businesses in the regions — strike a sharp contrast with the approach taken in framework deals reached by President Donald Trump. Here, Law360 examines four takeaways from the two trade agreements announced by the EU.
-
February 06, 2026
Trump Orders 25% Tariff For Countries With Biz Ties To Iran
President Donald Trump signed an executive order Friday afternoon that threatens a 25% tariff on the imports entering the U.S. of countries found to be purchasing goods or services from Iran.
-
February 06, 2026
Partnership Asks Justices To Restore $23M Loss Deduction
A partnership asked the U.S. Supreme Court to revive its $23 million loss deduction involving a Brazilian company, saying in a petition docketed Friday that the Second Circuit wrongly blocked a key argument and that an IRS anti-abuse regulation applied against the partnership should be invalidated.
-
February 06, 2026
Gov'ts Want Safeguards For Tax Data Swaps In UN Pact
The United Nations' framework convention on international tax cooperation must ensure that exchanges of taxpayer information take place only when the information is foreseeably relevant to the requesting government's enforcement of tax laws, several representatives said Friday during negotiations.
-
February 06, 2026
Buchanan Ingersoll Adds 2 Veteran Tax Pros In DC
Buchanan Ingersoll & Rooney PC has expanded its tax offerings in the nation's capital with two attorneys, including the former co-chair of the tax and private wealth practice at Whiteford Taylor & Preston LLP.
-
February 06, 2026
Gunster Brings On Longtime Tax Law Professor In Florida
Florida business law firm Gunster has added an experienced tax law professor to its ranks as of counsel.
-
February 06, 2026
Taxation With Representation: Gibson Dunn, S&C, Wachtell
In this week's Taxation With Representation, Elon Musk announces SpaceX's acquisition of his artificial intelligence company xAI, Devon Energy and Coterra Energy agree to merge, and Banco Santander SA acquires Webster Financial Corp.
-
February 06, 2026
CPAs Suggest Treasury Scrap Doc Plans For CFC Rules
The U.S. Treasury Department should rethink planned documentation requirements for overseas income allocations, the American Institute of Certified Public Accountants recommended in a letter released Friday, saying the rules may be unnecessarily burdensome.
-
February 05, 2026
Russian Scientist's US Wages Not Tax-Exempt, Tax Court Says
The U.S. Department of Energy's payments to a Russian scientist for subatomic particle research in Virginia don't fall under a U.S.-Russia tax treaty covering tax-exempt grants, the U.S. Tax Court held Thursday.
-
February 05, 2026
UN Talks Aim To Identify Gaps On Harmful Tax Practices
Representatives of governments asked their colleagues Thursday to pinpoint gaps in ongoing efforts to address harmful tax practices in order to sharpen the United Nations' framework convention on international tax cooperation.
-
February 05, 2026
Ga. Law Firm's CTA Challenge 'Hypothetical,' Feds Argue
The U.S. Treasury Department has asked a federal judge to toss a Georgia lawyer's suit alleging that the 2021 Corporate Transparency Act could force him to violate attorney-client privilege, arguing the suit is based on future "hypothetical changes" to the federal policy of nonenforcement.
-
February 05, 2026
Hostages Aren't Receiving Tax Relief, TIGTA Says
Recently released hostages did not receive tax relief despite the Internal Revenue Service implementing new procedures to improve the process to provide tax relief to taxpayers wrongfully detained or taken hostage, the Treasury Inspector General for Tax Administration said in a report released Thursday.
-
February 04, 2026
Developing Nations See Tax Data Swaps Lacking Reciprocity
Developing countries' requests for taxpayer information are often denied by other countries even as the resource-strapped nations have invested resources in fulfilling incoming requests, government officials said Wednesday.
-
February 04, 2026
Tax Group Of The Year: Davis Polk
Davis Polk & Wardwell LLP scored a significant victory for Exxon Mobil in litigation concerning the tax treatment of a major partnership with Qatar and oversaw several other complex, high-stakes transactions, earning it recognition as a 2025 Law360 Tax Practice Group of the Year.
-
February 04, 2026
IRS Urges Tax Court To Cut $315M From Siemens Deduction
The Internal Revenue Service defended its slashing of $315 million from a tax deduction that medical giant Siemens claimed on payments from overseas, telling the U.S. Tax Court that rule writers had congressional backing to issue the regulations underpinning the adjustment.
Expert Analysis
-
Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
-
E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
-
A Cold War-Era History Lesson On Due Process
The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.
-
How BigLaw Executive Orders May Affect Smaller Firms
Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.
-
Lawsuits Shouldn't Be Shadow Assets For Foreign Capital
Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.
-
How To Accelerate Your Post-Attorney Career Transition
Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.
-
Tariffs And FCA Create Perfect Storm For Importers
The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.
-
US Reassessment Of OECD Tax Deal Is Right Move
The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.
-
Measuring And Mitigating Harm From Discriminatory Taxes
In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.
-
Adapting To Private Practice: From DOJ Leadership To BigLaw
The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.
-
How The CRE Industry Is Adapting To Tariff Uncertainty
Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.
-
Law Firm Executive Orders Create A Legal Ethics Minefield
Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.
-
Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike
The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.