International

  • March 14, 2025

    Judge Splits $79M Judgment In Danish Tax Fraud Case

    A New York federal judge divided a nearly $79 million judgment against four investors and their pension plans after a jury in February found them liable for participating in a tax fraud scheme against the Danish government.  

  • March 14, 2025

    Ex-Greenberg Traurig Atty Ordered To Pay $15.5M To IRS

    A former Greenberg Traurig LLP attorney who was sentenced to prison for helping a musician skirt taxes owes $15.5 million in restitution to the Internal Revenue Service, a New York federal judge ruled.

  • March 14, 2025

    Taxation With Representation: Davis Polk, Paul Weiss

    In this week's Taxation With Representation, Mallinckrodt PLC and Endo Inc. combine, Rocket Cos. buys Redfin, and Endo divests its international pharmaceuticals business to Knight Therapeutics Inc.

  • March 14, 2025

    Struck-Off Lawyer Can't Lift Ban After Misleading HMRC

    A former consultant solicitor who misled HM Revenue and Customs to get a refund on stamp duty land tax has failed to have his professional ban lifted as a London court ruled on Friday that the sanction was fair and justified.

  • March 13, 2025

    Texan Calls $1.7M In FBAR Penalties Unconstitutional

    Constitutional law bars the United States from imposing $1.7 million in penalties for failure to report foreign bank accounts, a Texan said in urging a federal court to dismiss such an assessment against her.

  • March 13, 2025

    Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told

    The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.

  • March 13, 2025

    Australia Clarifying Managed Investment Trust Tax Regime

    The Australian government is planning to update its income tax laws to make it clear that trusts ultimately owned by a foreign pension fund can use certain concessional withholding tax rates on eligible distributions to members, the country's assistant treasurer said Thursday. 

  • March 13, 2025

    Belgian Firm Can Nix Dividends From Tax Base, Court Rules

    A Belgian engineering company was entitled to reduce its tax base by excluding dividends from its subsidiaries in member states before taxation, as per EU law and contrary to Belgian law, the Court of Justice of the European Union said in a preliminary ruling Thursday.

  • March 13, 2025

    Former IRS Counsel Joins Hinshaw In Chicago

    Hinshaw & Culbertson LLP announced that a longtime government attorney who most recently served as deputy managing counsel of the Internal Revenue Service Office of Chief Counsel in Chicago, has joined the firm's government practice as a partner.

  • March 13, 2025

    Akin's Energy Transition Group Grows With V&E Tax Atty

    Akin Gump Strauss Hauer & Feld LLP has hired a Vinson & Elkins LLP tax counsel who has spent the past decade counseling clients on the federal income tax aspects of energy transition transactions, the firm announced Thursday.

  • March 13, 2025

    5th Circ. Asks If Enforcement Delay Affects CTA Challenge

    The Fifth Circuit has asked for supplemental briefing in a challenge against the Corporate Transparency Act, asking whether the case is affected by the U.S. Treasury Department's recent decision to suspend enforcement of reporting rules for domestic companies.

  • March 13, 2025

    Trump's EU Threat May Aim To Boost Negotiation Leverage

    President Donald Trump continued his trade tactics Thursday, threatening a 200% tariff on European alcohol imports that is almost certain to be another tool to leverage in future negotiations despite the economic uncertainty it creates.

  • March 13, 2025

    Funding Deficiency May Hinder UN Tax Talks, Group Says

    Governments interested in pursuing a United Nations tax convention should step up funding for the organization, which is facing a budget shortfall, according to the Tax Justice Network, as U.S. arrears drag on quicker-than-usual funding from other countries.

  • March 13, 2025

    Insurance Brokers Could Get Tax Refunds After Court Ruling

    U.K. insurance brokers could be in line for tax refunds from the state worth up to £400 million ($518 million) after a landmark court case, according to accountancy MHA.

  • March 13, 2025

    Wait To File Taxes If You Have Capital Gains, Canada Says

    The Canada Revenue Agency recommended that taxpayers with capital gains wait to file their tax returns as it finalizes updates to its system to account for the delayed proposed increase in the inclusion rate, saying it will waive late-filing penalties.

  • March 12, 2025

    OECD Calls On Costa Rica To Limit Regressive Exemptions

    Costa Rica's tax revenue makes up just 25% of the country's gross domestic product, thanks in part to regressive exemptions to value-added and personal income taxes and its overall narrow tax bases, the Organization for Economic Cooperation and Development said.

  • March 12, 2025

    Judge Tosses Tax Fraud Claim In Mariana Bribery Case

    A federal court dismissed Wednesday a claim connected to allegations of tax fraud in a $310,000 civil asset forfeiture case brought by the U.S. government against a Northern Mariana Islands business after concluding the court lacked jurisdiction.

  • March 12, 2025

    Starbucks' Sourcing Aided $1.3B Low-Tax Profits, Report Says

    Starbucks leveraged its private certification program for coffee growers to boost profits transferred almost tax-free from Switzerland to the Netherlands to the U.K., amounting to an estimated $1.3 billion between 2011 and 2021, according to a report from a union-funded nonprofit organization.

  • March 12, 2025

    Tariffs Prompt Chipmakers To Look At Manufacturing Moves

    The U.S. semiconductor industry is considering moving manufacturing operations to the U.S. and elsewhere as a tariff-mitigation strategy with President Donald Trump threatening to levy the sector and its supply chains, professionals told Law360.

  • March 12, 2025

    EU E-Commerce Group Calls For Extended DST Moratorium

    The expiration of an agreement pausing implementation of digital services taxes comes as the entirety of the OECD's two-pillar agreement on international taxes leaves impacted businesses in uncertain waters, a European Union business group said in a letter, seeking an extension of the moratorium.

  • March 12, 2025

    EU Targets US Goods In Response To Trump's Tariffs

    The European Commission said Wednesday that it will impose tariffs on American goods imported into the European Union in response to U.S. tariffs placed on EU steel and aluminum exports.

  • March 12, 2025

    Spain Referred To CJEU Over Nonresident Tax Treatment

    Spain will have to face the Court of Justice of the European Union over what the European Commission said is a discriminatory capital gains tax regime because of a deferral available to residents that is not available to nonresidents.

  • March 12, 2025

    HMRC To Reward Whistleblowers Who Expose Tax Fraud

    Insiders who tip off investigators to serious tax avoidance by large companies and rich elites will be paid a cut of any money the U.K. tax enforcer claws back under a new policy proposed by the government.

  • March 11, 2025

    Canada's Incoming PM Pledges To Kill Capital Gains Tax Hike

    Canada's newly elected Prime Minister-designate Mark Carney said during his election victory speech that he would spike a controversial proposed increase to the country's capital gains tax, according to local media.

  • March 11, 2025

    Trump, Ontario Back Down After Two-Day Trade Flare-Up

    President Donald Trump called off additional tariffs on Canadian steel and aluminum Tuesday after the Ontario government dropped a briefly imposed surcharge on electricity exports, the White House told Law360 on Tuesday evening. 

Expert Analysis

  • Navigating A Potpourri Of Possible Transparency Act Pitfalls

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    Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.

  • How Methods Are Evolving In Textualist Interpretations

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    Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.

  • Why Attorneys Should Consider Community Leadership Roles

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    Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.

  • Firms Must Offer A Trifecta Of Services In Post-Chevron World

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    After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.

  • 5 Tips To Succeed In A Master Of Laws Program And Beyond

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    As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.

  • How Law Firms Can Avoid 'Collaboration Drag'

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    Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.

  • Litigation Funding Disclosure Key To Open, Impartial Process

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    Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.

  • What NFL Draft Picks Have In Common With Lateral Law Hires

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    Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.

  • Replacing The Stigma Of Menopause With Law Firm Support

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    A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.

  • Planning Law Firm Content Calendars: What, When, Where

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    During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

  • It's Time For A BigLaw Associates' Union

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    As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.

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