International

  • November 05, 2025

    Docs Show IRS Improperly Shared Data With ICE, Groups Say

    Documents submitted by the U.S. government to a D.C. federal court show the IRS violated taxpayer privacy laws by sharing individuals' addresses with ICE despite its requests lacking required information and by accepting an unreasonable explanation about why the information was requested, several groups said.

  • November 05, 2025

    Justices Skeptical About Trump's Emergency Tariff Authority

    Several U.S. Supreme Court justices asked the government to defend why well-established judicial doctrines shouldn't limit President Donald Trump's tariffs imposed under the International Emergency Economic Powers Act during oral arguments Wednesday, casting doubt on whether they believe the law provides that kind of authority.

  • November 05, 2025

    Poland Publishes Draft Of Global Pillar 2 Information Return

    Poland's Ministry of Finance on Wednesday published a draft of legislation to implement a first-of-its-kind global information return that countries will use to carry out an international 15% minimum corporate tax agreement known as Pillar Two.

  • November 05, 2025

    Switzerland Adopts Tax Treaty With Zimbabwe

    Switzerland has adopted the dispatch on the double taxation agreement with Zimbabwe as part of expanding its tax treaty network in the region, the Swiss government announced Wednesday.

  • November 04, 2025

    Malawi Asks Judge To Undo Halt Of Gem Export Tax Probe

    Malawi asked a Washington federal judge to reconsider his recent decision to bar the country from pursuing discovery against a gemstone company that it alleges partnered with a mining outfit to dodge billions of dollars in taxes and export royalties.

  • November 04, 2025

    Former Eaton CFO Says Bond Investors Needed Reassurance

    Eaton Corp.'s former chief financial officer chronicled on Tuesday the company's efforts to finance its 2012 acquisition of Ireland-based Cooper Industries, describing an atmosphere of leery bond investors after the Great Recession of 2008, on the second day of the company's U.S. Tax Court trial.

  • November 04, 2025

    Canadian Budget Proposes Slew Of Corporate Tax Breaks

    Canada's government aims to introduce immediate expensing for manufacturing, energy, data network infrastructure and scientific research while reinstating first-year write-offs for most capital assets, which would lower its marginal effective corporate tax rate to 13.2%, according to a budget presented late Tuesday.

  • November 04, 2025

    3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs

    A U.S. Supreme Court ruling that gutted deference to agencies took center stage in the Eighth Circuit's recent decision that backed 3M's challenge to transfer pricing rules, signaling the strict statutory analysis that courts may now apply to tax regulations.

  • November 04, 2025

    Higher Min. Tax Could Help Stem Inequality, G20 Report Says

    A higher minimum corporate tax rate with fewer carveouts, tougher inheritance taxes and a global asset registry would help stem economic inequality seen in the vast majority of countries, according to the Group of 20 nations' first report on inequality, published Tuesday.

  • November 04, 2025

    Insolvent UK Co.'s Ex-Director Fights £2M VAT Fraud Case

    The former director of a company in liquidation denied an insolvency specialist's claims that he took part in a value-added tax fraud at the business and is liable for paying about £2 million ($2.6 million), saying the U.K. tax authority has withdrawn its liability notices against him.

  • November 03, 2025

    Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told

    An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determining a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."

  • November 03, 2025

    4 Ways Justices' Jarkesy Ruling Could Affect Tax Controversy

    As lower courts have begun to weigh the U.S. Supreme Court’s 2024 ruling that the SEC’s imposition of civil penalties without a jury trial was unconstitutional, attorneys say the decision could reshape tax disputes and potentially force the IRS to reconsider its approach to enforcement. Here, Law360 examines potential ways the Jarkesy precedent could influence tax controversy.

  • November 03, 2025

    2 Doctrines Likely To Direct Justices' Review Of Trump Tariffs

    When the U.S. Supreme Court hears oral arguments Wednesday over whether President Donald Trump can impose tariffs under the International Emergency Economic Powers Act, it will likely test two doctrines the justices have recently considered: the major questions and nondelegation doctrines.

  • November 03, 2025

    Kenya Seeks Input On Regs For Min. Tax, Advance Pricing

    Kenya's tax authority invited feedback Monday for draft regulations covering its domestic minimum top-up tax and a separate set of draft regulations for its program to offer advance pricing agreements.

  • November 03, 2025

    US, China Agree To Cut Tariffs, Restrictions In Trade Truce

    The United States and China have agreed to a one-year suspension of certain tariffs, export controls and retaliatory trade restrictions, according to statements by the White House and China's Ministry of Commerce.

  • November 03, 2025

    Veteran Tax Controversy Atty Moves Team To Kostelanetz

    A longtime New Jersey tax attorney and three of his associates have joined Kostelanetz LLP, the boutique tax firm announced Monday, saying it expected them to bolster its tax controversy practice and add to its commitment to volunteer work and legal education.

  • November 03, 2025

    ECJ Asked To Clarify State Aid Tax Rules For Nonprofits

    A German court has asked the European Union's top court to rule on whether a tax relief scheme for nonprofit service corporations amounts to state aid under EU law, according to a notice published Monday.

  • November 03, 2025

    €1.2B Of Campari Owner's Shares Seized In Italian Tax Probe

    Italian authorities have seized about €1.2 billion ($1.4 billion) worth of shares in Campari Group as part of a tax investigation into the drink maker's Luxembourg-based majority stakeholder, which announced the asset seizure.

  • October 31, 2025

    Int'l Tax In October: Deal With China, Halt To Canada Talks

    A tentative deal to reduce American tariffs on Chinese goods, ruptured trade talks between the U.S. and Canada, court defeats for the Danish and U.S. tax administrations and an end to the European Union's plan for a financial transaction tax topped the list of international tax news in October. Here, Law360 looks at the biggest developments from the past month.

  • October 31, 2025

    Up Next At High Court: Tariffs, Fugitives & Contractor Liability

    The U.S. Supreme Court will begin its November oral argument session Monday, during which the justices will consider President Donald Trump's authority to impose tariffs on foreign countries under an emergency statute, whether military contractors can be held liable for alleged breaches of contracts in war zones, and if there are time limits for litigants who want to vacate a void judgment. Here, Law360 breaks down the week's oral arguments.

  • October 31, 2025

    OECD Reports Rise In Failed Advance Pricing Agreements

    The number of advance pricing agreements that were rejected or closed without an accord rose 19% last year compared with the previous year, and slightly fewer agreements were granted overall, the Organization for Economic Cooperation and Developmen said Friday.

  • October 31, 2025

    UK Co. Can't Shake £8.4M Tax On Goods Imported For Repair

    A U.K. subsidiary of a U.S. industrial equipment company isn't entitled to recover roughly £8.4 million ($11 million) in value-added tax on goods it brought into the U.K. for repair and servicing, a London tribunal ruled.

  • October 31, 2025

    OECD Reports Sharp Uptick In Transfer Pricing Dispute Cases

    Tax authorities began more than 2,500 mutual agreement procedure cases last year involving transfer pricing, a record number representing a 29% increase from the previous year, the Organization for Economic Cooperation and Development said Friday.

  • October 31, 2025

    Taxation With Representation: Skadden, Davis Polk

    In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.

  • October 31, 2025

    Australia Issues Guidance On Public Country-By-Country Law

    Australia issued guidance Friday on how to comply with its public country-by-country reporting law, including filing instructions, formatting and the information required to be disclosed.

Expert Analysis

  • 6 Changes I Would Make If I Ran A Law School

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    Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.

  • Firms Still Have The Edge In Lateral Hiring, But Buyer Beware

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    Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.

  • Think Like A Lawyer: 1 Type Of Case Complexity Stands Out

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    In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.

  • Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity

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    Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Reframing Document Review

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    For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.

  • 3 Ways To Train Junior Lawyers In 30 Minutes Or Less

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    Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.

  • The Bar Needs More Clarity On The Discovery Objection Rule

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    Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.

  • So You Want To Move Your Law Practice To Canada, Eh?

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    Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.

  • Promoting Diversity In The Selection Of ADR Neutrals

    Excerpt from Practical Guidance
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    Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.

  • Striking A Balance Between AI Use And Attorney Well-Being

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    As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.

  • How Judiciary Can Minimize AI Risks In Secondary Sources

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    Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.

  • How Attorneys Can Break Free From Career Enmeshment

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    Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.

  • Lawyers With Disabilities Are Seeking Equity, Not Pity

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    Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.

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