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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

Minnesota Property Tax Petition Extension Applies in Tax Court

By Amy Hodges | 01/18/2022

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

By Joseph J. Thorndike | 01/10/2022

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

By Jinyan Li | 01/10/2022

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

David D. Stewart, Stephanie Soong Johnston, and William H. "Will" Morris | 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.

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