International

  • April 07, 2026

    Partnership Wants Tax Court To Reconsider Basis Question

    A partnership asked the U.S. Tax Court to reconsider its finding that a company contributing a promissory note for a stake in the partnership had zero basis in the note, saying basis must be determined when a note is contributed, not at its conception.

  • April 07, 2026

    UK Oil Co. Can Avoid £167M Tax Assessment, Tribunal Says

    A U.K. oil company isn't liable for a £167 million ($221 million) increase to its taxable profits because for tax purposes it shouldn't be treated as having acquired an oil-related business following an intra-group transfer, according to an Upper Tribunal decision published Tuesday.

  • April 07, 2026

    IRS Updates Foreign Housing Expense Limits For 2026

    The Internal Revenue Service released adjustments Tuesday to the limitation on foreign housing expense deductions and exclusions for 2026.

  • April 07, 2026

    HMRC Clarifies Tax Relief For Investors Moving To UK

    Individuals who moved to the U.K. in recent years have until the end of January 2028 to file for tax relief under the foreign income and capital gains regime, Britain's tax authority said in new guidance Tuesday.

  • April 07, 2026

    Floridian Says Jury Was Required Before $20M FBAR Fine

    A dual U.S.-German citizen urged a Florida federal court to reject a magistrate judge's recommendation to uphold a nearly $20 million tax judgment for undisclosed foreign bank account information, contending the judge failed to recognize a recent change in the law about access to jury trials. 

  • April 08, 2026

    CORRECTED: HMRC Takes On New Powers As Tax Dodge Measures Kick In

    HM Revenue and Customs has assumed new powers to tackle tax fraud and evasion as key parts of new legislation take effect, including tougher rules on construction industry schemes and penalties for promoters of tax avoidance arrangements. Correction: A previous version of this article misstated which HMRC reforms took effect on April 6. The error has been corrected.

  • April 06, 2026

    Chewy Investor Settles Suit Against BC Partners For $29.5M

    A Chewy Inc. investor has brokered a $29.5 million deal with BC Partners that, if finalized, would settle the investor's derivative suit that alleged BC Partners saddled Chewy investors with potential tax liabilities following a financially unfair downstream merger involving PetSmart Inc., the parties told the Delaware Chancery Court on Monday.

  • April 06, 2026

    IRS' Proposed Voluntary Disclosure Rule Could Be Dissuasive

    The IRS has proposed relaxing the 75% civil fraud penalty for participants in its voluntary disclosure program, but a corresponding 90-day deadline for complying with all payment and filing requirements could discourage some taxpayers from coming forward.

  • April 06, 2026

    Germany, Italy Ask EU For Windfall Tax On Energy Companies

    Germany, Italy, Spain, Austria and Portugal have asked the European Union to create a windfall profits tax on energy companies so governments can finance relief for spiking oil prices fueled by the U.S. and Israel's war with Iran, the EU and three finance ministries told Law360 on Monday.

  • April 06, 2026

    Activewear Co. Fabletics Sued Again For Tariff Refunds

    Fabletics, the activewear company cofounded by actress Kate Hudson, was hit with a proposed class action in California federal court Friday alleging it is improperly pocketing tariff surcharges from customers and is refusing to commit to refunds, weeks after a similar suit was filed in Illinois state court.

  • April 06, 2026

    Int'l Tax In March: Tariff Refunds Coming Amid New Disputes

    Tariffs dominated the headlines in March, with the process for refunding those illegally imposed under the International Emergency Economic Powers Act being set up — and customers demanding their cut from businesses. Here, Law360 looks at these and other international tax developments from last month.

  • April 03, 2026

    Iran War's Trade Fallout Likely To Spread Beyond Oil, Fertilizer

    The war in Iran has already shocked oil and gas prices worldwide and stakeholders expect further U.S. trade consequences related to the conflict including supply chain constraints, cost increases across a variety of goods, and industries and new geopolitical responses as the conflict continues.

  • April 03, 2026

    Australia Cuts Fuel Tax Further As Iran War Spikes Prices

    Australia will reduce its fuel excise tax by nearly 11% on top of an already halved rate to offer consumers relief as oil prices have spiked in the wake of the U.S. and Israel's war in Iran, Prime Minister Anthony Albanese said.

  • April 03, 2026

    Man Denies Owing Gov't $19M In Biofuel Tax Credit Fraud

    A businessman told a Utah federal court that he shouldn't need to pay over $19 million for a forfeited loan from a company central to a $511 million biofuel tax credit fraud because the government's calculations are unjust and a government asset tricked him into withholding payment.

  • April 03, 2026

    Law360 Announces The Members Of Its 2026 Editorial Boards

    Law360 is pleased to announce the formation of its 2026 Editorial Advisory Boards.

  • April 03, 2026

    Taxation With Representation: Cleary, Hogan Lovells, Wachtell

    In this week's Taxation With Representation, spice maker McCormick acquires Unilever's foods business, wholesale restaurant food distributor Sysco buys Jetro Restaurant Depot, and private equity giant KKR closes a fund focused on investments in North America.

  • April 03, 2026

    EU Steel Group Says Carbon Tax Rules Need Tightening

    A European steel association urged policymakers Friday to close what it said are loopholes in the European Union's carbon tax system, arguing that legislative tweaks proposed by the bloc fall short.

  • April 02, 2026

    Trump Orders 100% Pharma Tariff, Modifies Metals Duties

    Later this year, the U.S. will impose 100% tariffs on imported pharmaceuticals, but drug companies could qualify for reduced tariff rates as low as zero if they agree to invest domestically and enter most-favored-nation drug-pricing agreements with the government, according to an executive order President Donald Trump signed Thursday.

  • April 02, 2026

    US Tariffs Hiked Consumer Prices By 0.5% To 1%, Report Says

    The U.S. government's tariffs imposed last year likely raised consumer prices by 0.5% to 1%, the Yale Budget Lab said Thursday in a report that revised down its initial estimates.

  • April 02, 2026

    Inheritance Tax Changes To Hit Investment, Advisers Warn

    The U.K. government's plans to slash tax relief for inheritance tax on agricultural and business property coming into effect Monday will hit investors and family businesses, advisers told Law360.

  • April 02, 2026

    $3.6T Of Untaxed Personal Wealth Held Offshore, Oxfam Says

    About $3.6 trillion in untaxed household wealth was held offshore in 2024, exceeding the poorer half of humanity's combined wealth by about $1 trillion, Oxfam International reported Thursday.

  • April 02, 2026

    Germany Moves To Cut Passenger Tax After Outcry By Airlines

    Germany advanced a proposal to slash an air passenger tax in an effort to improve the competitiveness of its aviation industry, walking back a 2024 rate hike.

  • April 02, 2026

    Investors Settle £4.3M Case Against Tax Refund Lender

    Two investment companies that sued a tax refund lender and its directors for more than £4.3 million ($5.7 million) in unpaid debt have agreed to settle their case.

  • April 01, 2026

    Apple's Top Irish Branch Had $1.4B Minimum Tax Bill In 2025

    Apple's top subsidiary in Ireland had a $1.4 billion top-up tax liability under the 15% global minimum tax during its 2025 fiscal year, part of a $12.1 billion tax bill, according to its annual financial statement.

  • April 01, 2026

    EU, Gibraltar Advance Deal With Intro Of Transaction Tax

    European Union countries advanced a post-Brexit deal concerning the British overseas territory of Gibraltar on Wednesday, which includes the introduction of a transaction tax to reduce competitive distortions with Spain, according to a Council of the EU news release.

Expert Analysis

  • What 2 Profs Noticed As Transactional Law Students Used AI

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    After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.

  • BigLaw Settlements Should Not Spur Ethics Deregulation

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    A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.

  • 5 Ways Lawyers Can Earn Back The Public's Trust

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    Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.

  • Legal Jeopardy Looms Over Trump's Trade Negotiation Plans

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    Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.

  • What US-India Trade Deal Will Mean For Indian Pharma

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    Complicated by newly imposed tariffs from the U.S., the outcome of the U.S.-India trade talks is poised to reshape not just trade policy, but also the strategic alignment of the two countries' pharmaceutical ecosystems, says Jashaswi Ghosh at Holon Law Partners.

  • Bar Exam Reform Must Expand Beyond A Single Updated Test

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    Recently released information about the National Conference of Bar Examiners’ new NextGen Uniform Bar Exam highlights why a single test is not ideal for measuring newly licensed lawyers’ competency, demonstrating the need for collaborative development, implementation and reform processes, says Gregory Bordelon at Suffolk University.

  • A Simple Way Courts Can Help Attys Avoid AI Hallucinations

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    As attorneys increasingly rely on generative artificial intelligence for legal research, courts should consider expanding online quality control programs to flag potential hallucinations — permitting counsel to correct mistakes and sparing judges the burden of imposing sanctions, say attorneys at Lankler Siffert & Wohl and Connors.

  • The Legal Education Status Quo Is No Longer Tenable

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    As underscored by the fallout from California’s February bar exam, legal education and licensure are tethered to outdated systems, and the industry must implement several key reforms to remain relevant and responsive to 21st century legal needs, says Matthew Nehmer at The Colleges of Law.

  • 6 Questions We Should Ask About The Trump Trade Deals

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    Whenever the text becomes available, certain questions will help determine whether the Trump administration’s trade deals with U.S. trading partners have been crafted to form durable economic relationships, or ephemeral ties likely to break upon interpretive disagreement or a change in political will, says Ted Posner at Baker Botts.

  • E-Discovery Quarterly: Rulings On Relevance Redactions

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    In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.

  • Section 1983 Has Promise After End Of Nationwide Injunctions

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    After the U.S. Supreme Court recently struck down the practice of nationwide injunctions in Trump v. Casa, Section 1983 civil rights suits can provide a better pathway to hold the government accountable — but this will require reforms to qualified immunity, says Marc Levin at the Council on Criminal Justice.

  • Playing Soccer Makes Me A Better Lawyer

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    Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.

  • Adapting To Private Practice: From ATF Director To BigLaw

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    As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.

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