International Tax: Insights from Law360 on Top International Tax Cases to Watch

Law360 recently published an article featuring Michael Kramarz, examining the top international tax cases corporations are litigating in the second half of 2026.

"This is a case study in what happens when a transfer pricing position goes unreviewed for too long," Kramarz said.

He also noted that oral arguments in the Coca-Cola case suggest the dispute may turn more on administrative fairness than transfer pricing mechanics, pointing to judges’ concerns about the government applying different pricing methods inconsistently across foreign affiliates.

For multinational businesses, these rulings signal that transfer pricing positions can’t be set once and left unexamined. Companies should periodically revisit their intercompany pricing methods and documentation to stay ahead of IRS scrutiny and shifting court precedent.

Read the full article in Law360.

Want to explore how international tax developments could affect your business? Connect with our International Tax team to learn more.