Opinions
Why Does Ireland Need a Participation Exemption?
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
Minnesota Property Tax Petition Extension Applies in Tax Court
The Minnesota Tax Court confirmed in Azhakh v. County of Hennepin and Samrah v. County of Hennepin that COVID-19-related extensions for filing property tax petitions apply in the state's tax court as well as its district courts.
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Featured Analysis
How ‘Tax Ferrets’ Revealed the Limits of Heavy-Handed Enforcement
Joseph J. Thorndike recounts the history of "tax ferrets," arguing that paying private tax collectors with a bounty system is a good way to ensure that the relationship between taxpayers and the state becomes as toxic and hostile as possible.
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Special Reports
Finding the Purpose of Tax Treaty Provisions Under GAAR: Lessons From Alta Energy
Jinyan Li considers the implications of the Supreme Court of Canada’s Alta Energy judgment for determining the purpose of tax treaty provisions under general antiabuse rules and suggests that a treaty’s text and context should carry more weight than inferred negotiator intentions.
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Tax Notes Talk
The Tax Diplomat: Reflections From Former BIAC Tax Chair
| January 13
Will Morris, former chair of the tax committee at Business at OECD, reflects on his nearly decadelong tenure and experiences leading the business community through OECD global corporate tax reform projects.