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Featured Analysis

In news analysis, Mindy Herzfeld examines a letter from the European Commission commenting on proposed regulations interpreting section 250, saying the commission’s reliance on a single report ignores historical nuances and that whether a tax measure can be considered a violation of a trade agreement because of its economic consequences is better analyzed within the context of the overall U.S. system.
In economic analysis, Martin A. Sullivan argues that Congress should pay for a lower effective tax rate on global intangible low-taxed income by increasing the 20 percent haircut on foreign creditable taxes, increase the haircut on foreign tax credits in 2026 instead of reducing the section 250 deduction, and reduce foreign tax creditability instead of raising the rate.
In news analysis, Marie Sapirie explains how nonprofit organizations are trying to balance the goal of benefiting low-income communities, as envisioned by the drafters of the Opportunity Zone regime, and the statutory framework that was enacted in the Tax Cuts and Jobs Act.