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Opinions

Tax Notes Editors' Wish List: Fall 2021

By Christopher Trigo | 09/10/2021

Calling all submissions! The top commentary editors of Tax Notes share the topics they hope to see covered this fall.

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Featured News

Shots Fired: Accounting Firms Weigh Vaccine Mandates and Reopenings

By Jonathan Curry | 09/10/2021

Vaccine mandates and office reopening schedules may vary among the nation’s leading accounting firms for now, but one thing they all agree on is a flexible workplace for the foreseeable future.

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Featured Analysis

A Scorecard for Reconciliation, Round 2

By Marie Sapirie | 09/13/2021

Marie Sapirie provides a list of likely changes that Congress will make as it moves toward a reconciliation bill, and she argues that the budget process as it is currently being used only increases the likelihood of churning tax rules, theatrics, and multiple rounds of technical corrections.

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Special Reports

Apple’s Cost-Sharing Arrangement: Frankenstein’s Monster, Part 2

By Stephen L. Curtis and David G. Chamberlain | 08/23/2021

Stephen L. Curtis and David G. Chamberlain apply the periodic adjustment rules to Apple’s cost-sharing
arrangement, and they propose alternative ways to tax some of the U.S. profit that Apple has been able to shift offshore by exploiting the cost-sharing regulations and other U.S. taxation mechanisms.

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Tax Notes Talk

Tracing the Global Minimum Tax Rule’s Path for Success

David D. Stewart, Nana Ama Sarfo, and Mark Strimber | September 09

Mark Strimber of RSM US LLP provides an overview of the global minimum tax rule featured in the OECD/G-20’s two-pillar project and discusses the effect it could have on various tax regimes.

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