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International

  • August 26, 2025

    Facebook Urges Tax Court To Toss IRS' Royalty Calculations

    Facebook asked the U.S. Tax Court to reject the IRS' proposed royalty rate and other calculations for the social media giant's deal with an Irish affiliate to develop intangibles, arguing the agency is attempting to recharacterize the transaction.

  • August 26, 2025

    South Korea Fined Taxpayers $189M For Unreported Accounts

    South Korea's tax authority meted out 263.3 billion won ($189 million) in fines to around 820 individuals last year for failing to disclose their foreign financial accounts after identifying them through intergovernmental exchanges of information, according to a report published Tuesday.

  • August 26, 2025

    EU Defends Digital Taxes Following Trump's Tariff Threat

    The European Commission said Tuesday that it stands by European Union member states keeping digital taxes in place despite President Donald Trump's renewed threats to impose tariffs on countries with measures hitting the U.S. tech giants.

  • August 26, 2025

    UAE's Domestic Min. Tax Qualified Under OECD Guidance

    The United Arab Emirates has completed a transitional self-certification process for its domestic minimum top-up tax so that it qualifies under the Organization for Economic Cooperation and Development's guidance for the 15% global minimum tax system, the country's Finance Ministry said.

  • August 25, 2025

    Advocate Orgs. Ask DC Circ. To Stop IRS Sharing Info With ICE

    Immigrant advocacy groups urged the D.C. Circuit to stop the IRS from sharing taxpayer addresses with immigration authorities, saying the court should consider the substance of their challenge to an unprecedented information sharing deal rather than toss their case on procedural grounds put forward by the government.

  • August 25, 2025

    Ex-TSA Attorney Among 3 New Lawyers At Kaplan Kirsch

    A former Transportation Security Administration attorney is among three lawyers who recently joined Kaplan Kirsch LLP, a Denver-based law firm that specializes in representing state, local and tribal government agencies on projects such as airport expansions and new rail lines.

  • August 25, 2025

    Romania Says Online Retailers Avoided VAT On $46M In Sales

    The Romanian government announced a large-scale operation against over 200 foreign e-commerce companies that it said have sold goods totaling about 200 million Romanian leu ($46 million) into the country without paying value-added taxes.

  • August 25, 2025

    Big 4 Urge Ireland To Boost R&D Tax Credit System

    Ireland should retool its research and development tax credit system, such as by increasing the credit's rate, to continue attracting investment in a changing international tax landscape, the Big Four accounting firms said in comments released Monday.

  • August 25, 2025

    Poland Planning Corp. Tax Increase On Banks, With Twist

    While Poland is planning a sizable increase to its corporate tax rate for banks, it also plans to cut another bank tax, the country's Ministry of Finance said.

  • August 22, 2025

    Liberty Global $240M Foreign Tax Credit Bid Fails At 10th Circ.

    Liberty Global cannot claim $240 million in foreign tax credits for the sale of a Japanese affiliate, the Tenth Circuit ruled Friday, rejecting the telecommunications giant's contention that a statutory provision allows it to recharacterize the proceeds as overseas income.

  • August 22, 2025

    Canada To Toss Tariffs On US Goods Under USMCA

    The Canadian government will remove retaliatory tariffs on U.S. goods that comply with the United States-Mexico-Canada Agreement, excluding steel, aluminum and automobiles, in a move aimed at jump-starting trade talks akin to an exemption made by the U.S. government, Canada's prime minister said Friday.

  • August 22, 2025

    HMRC Tightens Pension Tax Relief Claims By Higher Earners

    The U.K. is restricting pension tax relief claims for higher earners in a change coming into effect next month, Britain's tax authority said.

  • August 22, 2025

    Slovakian Gov't Proposes 3% To 5% Digital Services Tax

    Slovakia is proposing a digital services tax on companies including Meta, Google and Netflix, with a senior government official saying the ability of large tech companies to avoid Slovakian income taxes gives them an unfair advantage over local businesses.

  • August 22, 2025

    Taxation With Representation: Kirkland, Weil, Fried Frank

    In this week's Taxation With Representation, private equity firm Thoma Bravo buys human resources software provider Dayforce Inc. in a take-private deal, Lowe's buys Foundation Building Materials, Nexstar Media Group Inc. acquires fellow media company Tegna Inc., and Soho House & Co. Inc. inks a take-private deal with hotel operator MCR.

  • August 22, 2025

    IRS Guidance Sparks Mixed Reaction For Solar, Wind Projects

    The IRS recently narrowed the way large solar and wind energy development projects can set their construction start dates to qualify for certain tax credits, a change offering relief for some developers but new hurdles for others depending on the stage, type and size of the project.

  • August 22, 2025

    OECD Recognizes Brazil's Implementation Of Global Min. Tax

    The Organization for Economic Cooperation and Development has recognized Brazil's 15% corporate minimum tax as meeting the requirements for the international minimum tax framework known as Pillar Two, the country's Ministry of Finance announced.

  • August 21, 2025

    Omni Bridgeway Looks To Enforce $13M Albania Award

    Litigation funder Omni Bridgeway is urging a D.C. federal court to let it seize assets belonging to Albania as it looks to enforce an arbitral award now worth some $13 million that the country has ignored for years, in a nearly decade-old dispute stemming from taxes on oilfield projects.

  • August 21, 2025

    Man Who Hid Account From Wife Owes FBAR Fines, US Says

    A claim by the owner of a check-cashing business that he only meant to hide a foreign bank account from his wife during divorce proceedings doesn't excuse his failure to report the money to the Internal Revenue Service, the U.S. told a California federal court.

  • August 21, 2025

    EU, US Agree To Eliminate Industrial Tariffs

    The European Union and the U.S. have agreed on new terms to the trade agreement to eliminate EU tariffs on U.S. industrial products and implement a 15% U.S. tariff cap for most other sectors, according to a joint statement issued Thursday.

  • August 21, 2025

    Treasury Gets New Acting International Tax Counsel

    A deputy international tax counsel for the U.S. Department of the Treasury has been elevated to serve as acting counsel, he said in a post on LinkedIn.

  • August 21, 2025

    G7 Deal May Undermine Global Minimum Tax Enforcement

    The U.S. government's agreement with the Group of Seven nations to effectively exempt American companies from the 15% global minimum tax may hollow out enforcement of the international regime, in part because other multinational corporations may pursue similar treatment.

  • August 21, 2025

    Prosecutors Can Hunt Lawyer's Assets In Castle Fraud Case

    A London court ruled Thursday that prosecutors could go ahead with efforts to claw back money from a former lawyer who was imprisoned for more than a decade for defrauding an American property developer out of £10.5 million ($14 million.) 

  • August 21, 2025

    Health Insurance Uptick Fuels ÂŁ123M Rise In UK Tax Revenue

    Mounting pressure on Britain's public healthcare system is spurring the uptake of health insurance products and boosting government tax revenue, financial services consultancy Broadstone said Thursday.

  • August 20, 2025

    Australia Offers Compliance Guidelines For New Debt Rules

    The Australian Taxation Office published guidance Wednesday aimed at helping companies flag potential compliance risks as they reorganize in response to recent tax law changes that limit the amount of debt a corporation can use to fund its operations.

  • August 20, 2025

    IRS To Nix Recent Rules On Disregarded Foreign Payments

    The U.S. Treasury Department and IRS said Wednesday that they're planning to remove rules issued in January that would have forced companies to recognize income from payments that are disregarded for U.S. taxes yet reduce income in a foreign jurisdiction, a move prompted by criticism from businesses.

Expert Analysis

  • Mental Health First Aid: A Brief Primer For Attorneys

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    Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.

  • The Trade And Tax Issues Behind US-Canada Digital Tax Clash

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    The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.

  • Litigation Inspiration: Honoring Your Learned Profession

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    About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.

  • AI May Limit Key Learning Opportunities For Young Attorneys

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    The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.

  • Ruling On Foreign Dividend Break Offers 2 Tax Court Insights

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    In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.

  • Why Now Is The Time For Law Firms To Hire Lateral Partners

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    Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • Considering Possible PR Risks Of Certain Legal Tactics

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    Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.

  • It's No Longer Enough For Firms To Be Trusted Advisers

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    Amid fierce competition for business, the transactional “trusted adviser” paradigm from which most firms operate is no longer sufficient — they should instead aim to become trusted partners with their most valuable clients, says Stuart Maister at Strategic Narrative.

  • 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.

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