Opinions

The Battle of Assumptions in Facebook's U.S. Tax Court Case

By Ryan Finley | 05/26/2022

Recent testimony in the Tax Court's Facebook v. Commissioner trial highlighted a problem with the U.S. cost-sharing regulations, which establish valuation rules for a kind of related-party intangible property transfer that has long been popular among U.S. tech giants.

Featured News

Illinois Bill Would Clarify Application of PTE Tax to Retired Partners

By Benjamin Valdez | 02/03/2023

An Illinois lawmaker has proposed a bill that would tweak the state’s elective passthrough entity-level tax to exclude some retired members' income from the entity tax base.

Featured Analysis

Replacing Discontinued Interest Rates Does Not Trigger Gain or Loss

By Carrie Brandon Elliot | 02/06/2023

Carrie Brandon Elliot reviews the provisions in reg. section 1.1001-6 that govern contract modifications that transition away from discontinued interbank offered interest rates.

Special Reports

Compulsory Payments Under the Final FTC Regulations

By Brian H. Jenn and Mike Tenenboym | 05/09/2022

Brian H. Jenn and Mike Tenenboym explore how the new foreign tax credit regulations affect the compulsory payment rules.

Tax Notes Talk

Analyzing the Constraints of the OECD Corporate Mediation Process

David D. Stewart, Sarah Paez, Kiarra M. Strocko, Ariel S. Greenblum, and Abraham Leitner | February 02

Tax Notes reporters Sarah Paez and Kiarra Strocko discuss what they found in an exploration of the OECD-supported mediation process for multinational corporations.

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