International

  • March 24, 2025

    UK Gov't Considers DST Changes To Prevent US Tariffs

    The Labour government may be considering changes to the digital services tax as part of talks with the U.S. administration to prevent tariffs being imposed on Britain, Chancellor of the Exchequer Rachel Reeves suggested in a TV interview.

  • March 21, 2025

    Court Sours On Tribunal's Sweets Ruling For Marshmallows

    The First-tier Tribunal applied a faulty interpretation of value-added tax law to rule that jumbo-size marshmallows are exempt from VAT, a U.K. Court of Appeal panel said Friday, remanding the £473,000 ($611,000) dispute back to the tribunal.

  • March 21, 2025

    Ex-UBS North America CEO Agrees To $4.9M FBAR Judgment

    The former North American CEO for Swiss bank UBS on Friday agreed to a $4.9 million judgment to end claims that he failed to file timely or accurate foreign bank account reports with the Internal Revenue Service between 2003 and 2013.

  • March 21, 2025

    US-Swiss Agreement Exempts Retirees' Dividends, IRS Says

    U.S. retirement accounts, including trusts, qualified annuity plans and other schemes, are exempt from Swiss taxes on dividends from Swiss companies in which they don't own a controlling interest, according to a U.S.-Switzerland competent authority agreement released Friday by the IRS.

  • March 21, 2025

    Taxation With Representation: Cravath, Paul Weiss, Cooley

    In this week's Taxation With Representation, Google acquires Wiz, QXO Inc. acquires Beacon Roofing Supply, and the Boston Celtics are bought by a group led by private equity firm co-founder William Chisholm.

  • March 21, 2025

    Informal Money Transfers Launder £2B Annually, HMRC Warns

    Criminals in the U.K. are laundering an estimated £2 billion (£2.6 billion) every year via informal money transfer services, HM Revenue and Customs has warned.

  • March 21, 2025

    Spanish Lottery Co. Accused Of Tax Insurance Market Breach

    Spain's competition authority said Friday it is investigating a lottery company on suspicion of suppressing the marketing of tax insurance coverage for lottery winners.

  • March 20, 2025

    Corp. Taxes Should Match Climate Goals, OECD Paper Says

    Countries that want to reduce carbon emissions should design corporate income taxes that align with climate policy objectives, including providing incentives for clean energy investments, according to an OECD working paper released Thursday.

  • March 20, 2025

    Frost Brown Adds Former Houston City Atty To Finance Team

    Frost Brown Todd LLP announced that it has hired an attorney from the ranks of Houston's city government to strengthen its public finance group, adding his expertise in state and local government operations, taxation and economic development.

  • March 20, 2025

    PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.

    Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified.  

  • March 20, 2025

    90% Of Crypto Sellers Conceal Income, Danish Data Shows

    Danish Tax Agency data shows more than 90% of cryptocurrency sellers don't report that income and that many have shifted to foreign platforms to avoid domestic reporting rules, the EU Tax Observatory said in a working paper, suggesting international coordination is essential to tax crypto effectively.

  • March 20, 2025

    Prudential's £9.3M Fees To Silverfleet Taxable, HMRC Argues

    Prudential's payments of £9.3 million ($12 million) to an investment firm are taxable even though the fees were for services the firm carried out when the two companies were part of the same group, the tax authority's counsel told the U.K. Supreme Court on Thursday.

  • March 19, 2025

    IRS Hunter Biden Whistleblower Named Deputy Criminal Chief

    An Internal Revenue Service special agent who accused the U.S. Department of Justice of mishandling an investigation into former President Joe Biden's son has been named deputy chief in the IRS Criminal Investigation division, the agency said Wednesday.

  • March 19, 2025

    Coke's $2.7B Tax Bill Arbitrary, Business Groups Tell 11th Circ.

    Three industry groups asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming that the Internal Revenue Service could raise Coca-Cola's taxes by $2.7 billion, saying in friend-of-the-court briefs that the IRS acted arbitrarily in hiking the Atlanta-based beverage giant's tax liability.

  • March 19, 2025

    Sweden Proposes Cutting Some Green Energy Tax Breaks

    Sweden's Ministry of Finance is proposing that the government slash a pair of green energy tax benefits, one for the installation of solar panels and the other related to the microproduction of renewable energy.

  • March 19, 2025

    Technical, Policy Questions Still Swirl Around Amount B

    U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.

  • March 19, 2025

    DC Judge Won't Preemptively Stop IRS Data Sharing With DHS

    A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their bid for a court order that would preemptively block any information transfer.

  • March 19, 2025

    Switzerland, Zimbabwe Sign Tax Treaty

    Switzerland and Zimbabwe signed an agreement Wednesday for a treaty to avoid double taxation of income, an expansion of the Swiss treaty network in southern Africa that has been welcomed by cantons and businesses, according to Switzerland's competent authority.

  • March 19, 2025

    Law360 Announces The Members Of Its 2025 Editorial Boards

    Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.

  • March 19, 2025

    Group Status Prohibits VAT, Prudential Tells UK Top Court

    Prudential disputed a value-added tax claim on £9.3 million ($12.1 million) in performance fees at the U.K. Supreme Court on Wednesday on the grounds that the business providing the services was a part of the same group as Prudential for tax purposes. 

  • March 19, 2025

    Ex-Glencore Exec Fights £150M Tax On Offshore Shares

    Glencore's former head of oil urged an appeals court Wednesday to overturn a finding he was liable for income tax on nearly £150 million ($194 million) in share distributions from the Jersey company, in a case that could have wide implications on U.K. shareholders of offshore businesses.

  • March 19, 2025

    Disclosure Woes Sink £13M Fraud Trial Against Film Execs

    Prosecutors have abandoned a decade-long fraud case in which four former managers at a film production company were accused of cheating taxpayers out of £13 million ($17 million) because of insurmountable disclosure failures that sunk the case mid-trial.

  • March 18, 2025

    Tax Court Sides With IRS Deeming Debt 'Seriously Delinquent'

    A Florida man's tax debt was property certified by the Internal Revenue Service as "seriously delinquent" and reported to the U.S. secretary of state to bar him from obtaining or renewing a passport, the U.S. Tax Court said Tuesday.

  • March 18, 2025

    Danish Wind Farm Co. Wins UK Tax Relief For Study Costs

    A Danish wind farm company can claim expenditures on studies and designs associated with constructing wind farms for tax relief purposes, a London appeals court ruled.

  • March 18, 2025

    5 Jurisdictions Must Improve Tax Transparency, OECD Says

    Djibouti, the British Virgin Islands and three other jurisdictions have work to do to improve their compliance with global standards for tax transparency and exchange-of-information measures, according to reports published Tuesday by the Organization for Economic Cooperation and Development.

Expert Analysis

  • 5 Litigation Funding Trends To Note In 2025

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    Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.

  • Rethinking Litigation Risk And What It Really Means To Win

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    Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.

  • Small Biz Caught In Corporate Transparency Act Crossfire

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    Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.

  • No, Litigation Funders Are Not 'Fleeing' The District Of Del.

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    A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.

  • 5 E-Discovery Predictions For 2025 And Beyond

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    In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.

  • What's Ahead As Transparency Act Comes To A Crossroads

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    Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.

  • 7 Ways 2nd Trump Administration May Affect Partner Hiring

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    President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.

  • E-Discovery Quarterly: Rulings On Custodian Selection

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    Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.

  • Exploring Venue Strategy For Trump-Era Regulatory Litigation

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    Litigation will likely play a prominent role in shaping policy outcomes during the second Trump administration, and stakeholders have several tools at their disposal to steer regulatory litigation toward more favorable venues, say attorneys at Covington.

  • An Associate's Guide To Career Development In 2025

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    As the new year begins, associates at all levels should consider establishing career metrics, fostering key relationships and employing other specific strategies to help move through the complexities of the legal profession with confidence and emerge as trailblazers, say EJ Stern and Amanda George at Fractional Law Firm.

  • Making The Pitch To Grow Your Company's Legal Team

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    In a compressed economy, convincing the C-suite to invest in additional legal talent can be a herculean task, but a convincing pitch — supported by metrics and cost analyses — may help in-house counsel justify the growth of their team, say Elizabeth Smith and Roger Garceau at Major Lindsey.

  • Tax Court Should Update Framework For Defining Insurance

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    ​​​​​​​The U.S. Tax Court's unnecessary determination in Royalty Management Insurance v. Commissioner that a fraudulent transaction did not contain the hallmarks of a legitimate insurance transaction applies an outdated analysis that threatens the captive insurance sector and illustrates the need for a more modern framework to define true insurance, says Matthew Queen at the Queen Firm.

  • When US Privilege Law Applies To Docs Made Outside The US

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    As globalization manifests itself in disputes over foreign-created documents, a California federal court’s recent trademark decision illustrates nuances of both U.S. privilege frameworks and foreign evidentiary protections that attorneys must increasingly bear in mind, say attorneys at Hunton.

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