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Opinions

The Future of the Proposed Carried Interest Regulations

By Benjamin M. Willis and Monte A. Jackel | 08/06/2020

In this episode of Willis Weighs In, Benjamin M. Willis, Tax Notes Federal contributing editor, discusses carried interests with partnership tax expert Monte A. Jackel. Monte and Ben speculate on what the new regulations are expected to look like and provide their opinions on potential IRS overreaches likely to be overturned if potentially tenuous arguments are brought to court.

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Featured News

Virginia Prefiled Bill Would Exempt PPP Loan Forgiveness From Income Tax

By Lauren Loricchio | 08/10/2020

A Virginia Republican has prefiled legislation to provide tax relief to businesses, including by exempting loan forgiveness under the federal Paycheck Protection Program from state income tax.

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Featured Analysis

Economic Analysis: Who Would Get Enhanced Employee Retention Credits?

By Martin A. Sullivan | 08/10/2020

Martin A. Sullivan questions who would be eligible for an enhanced employee retention tax credit and argues that, given the complexity and ambiguity of the business suspension test, Congress and the IRS should seriously consider simpler safe harbor rules, particularly for small business.

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Special Reports

A Closer Look at Luxembourg’s Nondeductibility of Payments Draft Law

By Alex Pouchard | 08/03/2020

Alex Pouchard assesses the impact of Luxembourg’s proposed provision for the disallowance of some payments made to blacklisted jurisdictions on the Luxembourg investment fund industry in light of the widespread use of Cayman Islands fund vehicles.

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Tax Notes Talk

iWin: A Closer Look at Apple’s State Aid Victory

David D. Stewart, Ryan Finley, Stephanie Soong Johnston, Ariel S. Greenblum, and Alan I. Appel | August 06

Tax Notes chief correspondent Stephanie Soong Johnston and legal reporter Ryan Finley discuss Ireland and Apple Inc.’s state aid win with law professors Ruth Mason of the University of Virginia and Stephen Daly of King’s College London. In the segment "In the Pages Sneak Peek," Tax Notes Federal Editor in Chief Ariel Greenblum chats with Alan I. Appel, director of the international tax program at New York Law School, about his recent piece, "The Hidden Marriage Penalty Inside the TCJA."

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