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.
Andrew Wainer explains the need for - and challenges to - property taxation reform in Africa, focusing on the example of Kenya.
Carrie Brandon Elliot reviews how lower-tier subsidiaries of tested foreign corporations perform the asset test for PFIC status.
In this installment of State Tax Merry-Go-Round, Billy Hamilton examines the status of recent efforts to halt or limit states’ business tax incentives and finds that not much progress has been made so far.
Nana Ama Sarfo looks at trends from the OECD's latest Africa Initiative report and mentions some potentially helpful analysis for future reports.
Stanley R. Kaminski and Lauren A. Ferrante of Duane Morris LLP discuss the importance of properly changing state tax domiciles to achieve desired tax results — focusing on the California Office of Tax Appeals’ recent ruling in Bracamonte.
In this installment of The SALT Box, Roxanne Bland examines worldwide combined reporting — past, present, and future.
Victor Thuronyi argues that the IRC should be redrafted, and he proposes specific style changes, noting that the scope of the rewrite should be modest.
Pam Olson, Julie Goosman, Mark Smith, Larry Campbell, Josie Lowman, Surjya Mitra, Chris Riffle, Karl Russo, Morgan Siepel, and Christine Watson of PwC discuss the 2020 developments for corporate taxation, focusing on insurance companies.
Calvin H. Johnson argues that $6 trillion can be raised by requiring Apple, Amazon, Microsoft, and Google to capitalize intangible investments that have value beyond the end of the tax year and by reversing into income the companies’ prior deductions that are inconsistent with that value.
Benjamin M. Willis argues that closing the tax gap would be better achieved if Treasury and the IRS stopped relying on Chevron deference to create overly aggressive revenue-raising laws and appreciate why courts are favoring taxpayer interpretations.