International
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September 08, 2026
IRS Accepting Applications To 2027 Real-Time Audit Program
The Internal Revenue Service is accepting applications for its compliance assurance process real-time audit program for 2027, the agency announced Tuesday.
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September 08, 2026
Canada Defends Retaliatory Tariffs Against US As Necessary
Canadian Prime Minister Mark Carney defended Canada's retaliatory tariffs against the U.S. as they went into effect Tuesday, saying they are needed to protect Canadian workers and industries from President Donald Trump's latest trade war action.
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September 08, 2026
DC Circ. Affirms Injunction Against IRS-ICE Data Sharing
The D.C. Circuit affirmed a lower court's preliminary injunction Tuesday barring the IRS from sharing taxpayer data with immigration authorities, finding that the coalition challenging the deal has standing and that the arrangement likely violates the law.
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September 08, 2026
Biotech Company Pays £7.4M To Settle Russia Export Breach
The U.K. arm of an international genome sequencing company has paid a record £7.4 million ($10 million) for breaching export controls after it admitted to supplying sanctioned goods to Russia, HM Revenue & Customs said Tuesday.
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September 08, 2026
HMRC Sets Out £70K Cap In Loan Charge Tax Settlements
HM Revenue & Customs set out new guidance for the U.K.'s loan charge settlement scheme, including a five-step calculation, a cap of £70,000 ($94,600) on discounted payments and a time limit for taxpayers.
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September 08, 2026
HMRC Issues Post-Brexit Duty-Free Changes For Alcohol
Britain's tax authority said Tuesday that it's changing duty-free allowances on alcohol for travelers entering the U.K. starting in October as part of post-Brexit measures to simplify rules.
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September 08, 2026
EU Figure Defends Tax Data Guards Amid Exchange Concerns
Amid criticism that taxpayer privacy is not sufficiently protected, a European Union tax official said Tuesday that the bloc has strong measures in place to address data-protection breaches and protect taxpayers, such as the suspension of information sharing between member states.
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September 07, 2026
Healey Won't Rule Out Tax Hikes Despite Business Demands
Chancellor John Healey declined on Monday to rule out tax hikes in the autumn Budget statement despite demands from industry groups to reduce the fiscal pressure on businesses.
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September 07, 2026
EU Nations Fear Digital Tax Backlash Ahead of Budget Crunch
A number of European Union countries oppose the inclusion of a bloc-wide digital services tax in the EU's long-term budget because of its potential to aggravate geopolitical tensions, according to a Council of the European Union document seen by Law360 on Monday.
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September 04, 2026
4 Books Transfer Pricing Economists Think You Should Read
What do transfer pricing experts — economists, specifically — do in the summer? In July, many of them attend the National Association for Business Economics' annual transfer pricing symposium and discuss their favorite books with Law360 during the coffee breaks. Others were kind enough to do it during their regular work hours. Here, Law360 looks at four of their picks.
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September 04, 2026
Pfizer Can't Cut Ala. Tax With Shuffled Loans, Court Affirms
Pfizer cannot reduce its Alabama corporate income tax liabilities by deducting $658 million in interest payments made to an Irish affiliate that shuffled them to Luxembourg affiliates as tax-free dividends, the Alabama Court of Civil Appeals said Friday, affirming a lower court's decision.
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September 04, 2026
Hong Kong And Slovenia Sign Tax Treaty
Hong Kong and Slovenia signed a tax treaty Friday that would slash withholding tax rates for Hong Kong residents, according to the Inland Revenue Department.
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September 04, 2026
4th Circ. Affirms $2.9M IRS Fine For Unreported Accounts
The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclose offshore accounts to the IRS.
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September 04, 2026
Singapore's Tax Take Rises To $77B, Driven By Biz Tax
Singapore collected 97.3 billion Singapore dollars ($76.8 billion) in tax revenue during its 2025-26 fiscal year, about 9.4% more than the previous cycle, driven by corporate income tax, the country's Inland Revenue Authority said Friday.
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September 04, 2026
BlueCrest Ruling Sparks Tax Uncertainty For UK Firms
The U.K. Supreme Court's recent ruling that fund managers are taxable as employees rather than partners injects considerable uncertainty into the financial services industry, with companies potentially facing increased scrutiny from tax authorities and less predictable tax obligations.
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September 04, 2026
Spain Calls For EU Energy Firm Tax To Fund Climate Action
Spain called on the European Union to consider a levy on the profits of oil and gas companies to fund the region's response to the climate crisis, according to a letter and policy paper seen Friday by Law360.
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September 04, 2026
EU Countries Bristle At Tax Avoidance Rule Proposal
European Union member states are concerned that proposed changes to anti-tax avoidance rules, such as those that relate to how much interest companies can deduct from taxable profits, may result in revenue losses and an increased risk of tax abuse, EU officials told Law360 on Friday.
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September 03, 2026
Canadian Group Can't Blend Insurance Businesses' Income
A fraternal benefit society cannot blend its life insurance and accident insurance businesses for tax purposes, Canada's Federal Court of Appeal said, setting aside a lower court's decision.
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September 03, 2026
Australia Floats Bill For 30% Min. Tax On Discretionary Trusts
Australia is seeking feedback on a bill that would create a 30% minimum tax on discretionary trusts to better align tax rates on trust income and employment income, the Department of the Treasury said.
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September 03, 2026
Firm Must Give Client Docs To Tax Agency, Canada Court Says
A Toronto-based accounting firm must hand over client information to the Canada Revenue Agency, a Canadian appeals court ruled, holding that a lower court erred in giving the firm "a second kick at the can" in fighting to withhold documents.
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September 03, 2026
EU Council OKs Bloc Customs Modernization Program
A suite of changes aimed at modernizing the European Union's customs administration to help it handle the e-commerce boom is on the precipice of implementation after the Council of the EU approved them Thursday, teeing up a final vote in the European Parliament.
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September 03, 2026
EU Moves To Ease Armenia Tariffs After Russian Restrictions
The European Parliament's International Trade Committee on Thursday advanced a measure that would remove ad valorem duties on a swath of Armenian products to provide aid to the country in the wake of Russian trade restrictions.
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September 02, 2026
Airbnb Can't Nix IRS Expert In $1.3B Bill Fight, Tax Court Says
The U.S. Tax Court denied Airbnb's bid to strike IRS expert witness reports from discovery proceedings in the company's challenge against a $1.3 billion tax bill, ruling Wednesday that a procedural rule governing expert testimony applies only to trials.
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September 02, 2026
German Gov't Backs €10B Tax Break, 'Super-Rich Tax'
Germany's cabinet approved a bill Wednesday that would provide €10 billion ($11.6 billion) in tax relief to low- and middle-income taxpayers, partly funded by adding a 47% top rate for individuals that's been called a "super-rich tax" by the country's Finance Ministry.
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September 02, 2026
Austrian Asset Transfer Meets VAT Exception, EU Court Says
An Austrian man doesn't owe value-added taxes on the transfer of his buildings and other assets to a company he owned, the European Union's top court ruled Wednesday, holding that the transaction falls under an exception in EU VAT law.
Expert Analysis
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Navigating Antitrust Risks When Responding To Tariffs
Companies should assess competitive perils, implement compliance safeguards and document independent decision-making as they consider their responses to recent tariff pressures, say attorneys at White & Case.
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Key Points From HMRC's Tax Reform Proposals
Although HM Revenue & Customs’ recent proposals for reform of U.K. transfer pricing and permanent establishment rules align with the latest international consensus, certain amendments may lead to future controversy, say lawyers at Skadden.
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Adapting To Private Practice: From US Rep. To Boutique Firm
My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.
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IRS Should Work With Industry On Microcaptive Regs
The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.
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What To Note As UK Adopts OECD Crypto Disclosure Rules
With the U.K.’s recent announcement that it will adopt the Organization for Economic Cooperation and Development's crypto-asset reporting framework, users and providers will benefit from understanding the context surrounding the decision and the framework's intended goal of clamping down on tax evasion, say lawyers at Brown Rudnick.
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Senate's 41% Litigation Finance Tax Would Hurt Legal System
The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.
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Move Beyond Surface-Level Edits To Master Legal Writing
Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.
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9th Circ. Has Muddied Waters Of Article III Pleading Standard
District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.
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How AI May Reshape The Future Of Adjudication
As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.
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When Legal Advocacy Crosses The Line Into Incivility
As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.
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Attacks On Judicial Independence Tend To Manifest In 3 Ways
Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.
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Section 899 Could Be A Costly Tax Shift For US Borrowers
Intended to deter foreign governments from applying unfair taxes to U.S. companies, the proposal adding new Section 899 to the Internal Revenue Code would more likely increase tax burdens on U.S. borrowers than non-U.S. lenders unless Congress limits its scope, says Michael Bolotin at Debevoise.