International

  • August 19, 2026

    Treasury Floats Regs For Foreign-Derived Income Deduction

    The U.S. Treasury Department proposed regulations Wednesday that would clarify the 2025 federal budget bill's changes to the tax treatment of domestic businesses that sell into foreign markets, including clarifying the types of income that qualify for a deduction.

  • August 19, 2026

    Trump Delays Canada Tariffs, Says Deal Imminent

    President Donald Trump delayed for three days 50% tariffs on select Canadian goods scheduled to take effect Wednesday in an effort to strike a deal with the Canadian government, he said late Tuesday evening.

  • August 18, 2026

    Are Trump Diamond Tariff Breaks Tied To Gift? Wyden Asks

    Sen. Ron Wyden, D-Ore., on Tuesday demanded answers about President Donald Trump granting a tariff exemption for diamonds shortly after being given a gem-coated watch, claiming the circumstances may be tantamount to bribery, while also raising concerns about potential conflicts of interest in a separate duty investigation.

  • August 18, 2026

    Groups Ask Tax Court To Let Abbott Use IRS Appeals Office

    The U.S. Tax Court should deny the IRS a quick win on decreasing Abbott Laboratories' income eligible for deductions by about $380 million because the company is entitled to pursue several concerns first at the Independent Office of Appeals, two groups said in amicus briefs.

  • August 18, 2026

    Floridian Waived Jury Right In $20M FBAR Case, Judge Says

    A Florida federal judge upheld a nearly $20 million tax judgment against a dual U.S.-German citizen for undisclosed foreign bank account information, holding that he could not justify his delay in asserting his right to a jury trial.

  • August 18, 2026

    HMRC Opens Registration For Tax Advisers

    Britain's tax authority announced on Tuesday the opening of mandatory registration for tax advisers handling corporate tax matters.

  • August 18, 2026

    EU Guidance Lays Out Cost Adjustments For Carbon Levy

    The European Union's carbon import levy on emissions-intensive goods such as aluminum and cement will allow importers to reduce the cost of the levy to mirror carbon allowances granted to EU producers based on benchmark values, according to guidance from the bloc's executive.

  • August 17, 2026

    Ex-Goldman Exec Ordered To Pay $860K For Not Filing FBAR

    A D.C. federal judge on Monday ordered former Goldman Sachs banking executive Patricia L. Bowden to pay more than $860,000 in damages after she failed to take action in the federal government's lawsuit that alleged she willfully failed to report her Australian bank accounts to the Internal Revenue Service.

  • August 17, 2026

    Pitney Bowes Hit With Tariff Refund Suit By EBay Users

    EBay users hit Pitney Bowes Inc. with a breach of contract proposed class action Monday in Connecticut federal court alleging the global shipping and logistics company failed to return or refund them tariff-related charges that were deemed illegal by the U.S. Supreme Court earlier this year.

  • August 17, 2026

    Law Firm's Challenge To 2021 Statute Falls Short, Judge Says

    A Georgia federal judge on Monday dismissed a lawsuit brought by an attorney and his firm alleging a 2021 law designed to combat money laundering could force the attorney to violate attorney-client privilege, finding the plaintiffs had failed to allege any concrete injury that would empower them to pursue the case. 

  • August 17, 2026

    Split 10th Circ. Won't Revisit Liberty Global's $2.4B Tax Loss

    The Tenth Circuit said Monday it won't reconsider an April ruling against Liberty Global, upholding a decision that found the telecommunications giant improperly claimed a $2.4 billion deduction based on foreign transactions that lacked economic substance.

  • August 17, 2026

    Biz Pushes Class Cert. As Solution To IEEPA Refund Issues

    The U.S. Court of International Trade should grant class certification to companies seeking refunds of duties paid under the invalidated global tariff regime, the company serving as a test case for the refunds said in arguments mirroring those recently made in the underlying dispute.

  • August 17, 2026

    McKesson's $10M Tax Refund Bid Misreads Law, Gov't Says

    The U.S. government urged a Texas federal court to uphold transfer pricing regulations that McKesson is challenging in its push for a nearly $10 million tax refund, arguing the pharmaceutical giant has taken an overly narrow statutory reading.

  • August 17, 2026

    UnitedHealth Says IRS Seeking Transfer Pricing Adjustments

    The Internal Revenue Service has proposed transfer pricing adjustments for UnitedHealth Group Inc. that the company is disputing, according to a quarterly report.

  • August 17, 2026

    Atlassian Seeks To Reup Australia Advance Pricing Agreement

    Australian software company Atlassian Corp. is seeking to renew an advance pricing agreement with the Australian Taxation Office that produced a hefty settlement, the company said in its annual report.

  • August 14, 2026

    Meta's Litigation Distinct From Facebook's, IRS Says

    The case over Meta Platforms' 2017-2019 tax years is not identical to the one brought by its predecessor, Facebook, the IRS said in responding to Meta's claim that the government is seeking to relitigate the earlier dispute, which involved 2010.

  • August 14, 2026

    Rising Star: Baker McKenzie's Cameron Reilly

    Baker McKenzie partner Cameron Reilly helped secure a key tax court ruling for FedEx Corp. to invalidate regulations on mandatory repatriation under the 2017 federal tax changes, and was a lead attorney in Facebook Inc.'s successful challenge to cost-sharing regulations for multinational corporations, earning him a spot among the tax practitioners under 40 honored by Law360 as Rising Stars.

  • August 14, 2026

    UN Seeks Input On Draft Tax Convention And Protocols

    The United Nations is seeking input on a draft version of its proposed framework international tax convention, a protocol on taxing cross-border services and conventions on dispute prevention and resolution, the body's Department of Economic and Social Affairs said Friday.

  • August 14, 2026

    Taxation With Representation: Miller Thomson, Bennett Jones

    In this week's Taxation With Representation, GO Residential Real Estate Investment Trust and a consortium of buyers acquire H&R Real Estate Investment Trust, insurance exchange Accelerant goes private in a deal with Thoma Bravo, and Goldman Sachs acquires NEOS Investments.

  • August 14, 2026

    China's Tax Changes Leave Rich Rethinking Wealth Planning

    Changes to China's tax treatment of offshore trusts and a wider compliance cleanup have prompted wealthy investors to rethink strategies designed to lower their tax burdens, experts say.

  • August 14, 2026

    Coach Owner Reports $42M Global Min. Tax Bill In Singapore

    Tapestry, owner of the fashion brands Coach and Kate Spade, booked a $42.4 million charge for Singapore's qualified domestic minimum top-up tax in its latest annual report filed with the U.S. Securities and Exchange Commission.

  • August 14, 2026

    Cyberattack On French Tax Authority Exposes Data

    Data on individuals and businesses has been stolen in a cyberattack on France's tax authority, the country's Finance Ministry said.

  • August 14, 2026

    Maryland Tax Court Strikes Down Digital Advertising Tax

    Maryland's first-in-the-nation digital advertising tax violates the federal Internet Tax Freedom Act by applying only to electronic commerce, the state's tax court said in a group of decisions Friday, striking down the tax.

  • August 14, 2026

    Taxable Pension Withdrawals By Under-65s Reach £76B

    Britons under 65 have taken £75.5 billion ($102 billion) in taxable income from their pensions in just over a decade, an insurance technology company has said.

  • August 13, 2026

    Treasury Floats Foreign Currency Rules To Fix Timing Issues

    The U.S. Treasury Department proposed regulations Thursday that would smooth out timing wrinkles companies were facing when determining the taxable income of affiliates that conduct business in a foreign currency for 2025 returns.

Expert Analysis

  • What To Note As UK Adopts OECD Crypto Disclosure Rules

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    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.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    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.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    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.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    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.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

  • Attacks On Judicial Independence Tend To Manifest In 3 Ways

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    Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.

  • Section 899 Could Be A Costly Tax Shift For US Borrowers

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    Intended to deter foreign governments from applying unfair taxes to U.S. companies, the proposal adding new Section 899 to the Internal Revenue Code would more likely increase tax burdens on U.S. borrowers than non-U.S. lenders unless Congress limits its scope, says Michael Bolotin at Debevoise.

  • Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use

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    The recent revelation that a handful of questions from the controversial California bar exam administered in February were drafted using generative artificial intelligence demonstrates the continued importance of disclosure for attorneys who use AI tools, say attorneys at Troutman.

  • 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.

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