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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.

Karen C. Burke examines the problem of contributed zero-basis intangibles in light of the IRS’s inadvertent disclosure of a transaction structured by Bristol-Myers Squibb to shift billions of dollars of built-in gain to a related foreign partner.
Allison Christians considers the governance structure underlying the international tax framework and argues that the world would benefit from its fundamental transformation into a randomized and more equitable leadership structure, whether through existing institutions like the OECD's inclusive framework, or a new body, such as a global forum on tax governance.
Tax Notes State recognizes Harley Duncan of KPMG LLP as its person of the year, including an interview with senior editor Doug Sheppard and tributes by Dan R. Bucks, Verenda Smith, and Doug Lindholm.
As Congress debates whether to alter the $10,000 cap on the state and local tax deduction, some states -- with the IRS's blessing -- have created creditable passthrough entity-level taxes that can help business owners recapture the value of the full, uncapped deduction. But do those approaches help, or do they just add more complexity to an already confusing system? In a December 8 "Taxing Issues" webinar, panelists Steven N.J. Wlodychak, formerly of EY, Alysse McLoughlin of Jones Walker LLP, and Brian Reardon of the S Corporation Association and Reardon Consulting LLC joined Tax Analysts President and CEO Cara Griffith to examine states' SALT cap workarounds.