Featured Analysis
A curated selection of our standard-setting tax analysis and commentary. If you are looking for the Tax Notes difference, look no further.
In this installment of The SALT Box, Roxanne Bland examines Sirius XM Radio Inc. v. Hegar, a case accepted by the Texas Supreme Court. She writes that the Texas Court of Appeals, Third District’s illogical ruling that Sirius’s receipts should be attributed to Texas has flipped the state’s standard for attributing receipts on its head, and that hopefully the state supreme court will set it aright.
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.
Tax Notes International contributing editor Nana Ama Sarfo interviews Jiyeon Lee-Lim, global chair of Latham & Watkins’s tax department, about her philosophies on becoming a partner and leader in tax.
Philip Wolf interviews the professor who inspired him to pursue a career in tax.
Alice G. Abreu, Jacqueline Laínez Flanagan, and Peter Mason examine the lack of racial diversity in the tax profession and built-in biases in tax policies and suggest ways to remedy the inequities.
Benjamin Alarie and Bettina Xue Griffin examine the Tax Court’s decision in Reserve Mechanical and the strength of its appeal on the issue of whether the taxpayer was exempt from tax as a valid insurance company under section 501(c)(15).
Kathleen K. Wright of Golden Gate University San Francisco outlines grant programs established in California to help small business and the state and federal taxation of payments received under those programs.
Joseph J. Thorndike discusses two articles on U.S. tax imperialism in Puerto Rico and Cuba and explains how America’s form of economic subordination is not something of the past or limited to quasi-colonial territorial control.
Reuven S. Avi-Yonah critiques a recent U.S. tax reform proposal that would overhaul the global intangible low-taxed income, foreign-derived intangible income, and base erosion and antiabuse tax regimes.
Benjamin M. Willis argues that the Tax Cuts and Jobs Act continued the trend of imposing new taxes that erode the norms of income and realization, and he predicts that the reconciliation bill will follow suit.