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Why Does Ireland Need a Participation Exemption?

By Robert Goulder | 01/13/2022

Robert Goulder writes that Ireland, or any other country thinking about territorial tax reforms, should kick the tires before they commit to fundamental change.

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Featured News

Virginia Governor Pushes for Expanded Business Tax Relief

By Benjamin Valdez | 01/25/2022

Virginia Gov. Glenn Youngkin (R) has unveiled a legislative agenda that includes a boost to the state’s deduction for Paycheck Protection Program loan expenses and an income tax credit for small businesses.

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Featured Analysis

Does Strategic Forbearance Explain EU Deference to FATCA?

By Robert Goulder | 01/24/2022

Robert Goulder asks why EU officials habitually decline to enforce EU data protection rules whenever the Foreign Account Tax Compliance Act is involved.

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Special Reports

Reasonable IRS Appraisal Triggers Conservation Easement Settlement

By Hale E. Sheppard | 01/03/2022

Hale E. Sheppard examines a recent conservation easement donation dispute, Little Horse Creek Property, and explains several taxpayer-favorable holdings by the Tax Court, explores the strategic use of qualified offers, and argues that easement cases can be resolved when the IRS focuses on valuation instead of supposed technical flaws in documents.

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Tax Notes Talk

Looking Ahead to the 2022 Filing Season and What to Expect

David D. Stewart, Marie Sapirie, Beverly Winstead, and Paul Miller | January 20

Beverly Winstead of the Law Office of Beverly Winstead LLC and Paul Miller of Miller & Co. LLP discuss the 2022 filing season’s challenges and considerations in the third year of the pandemic.

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