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.
Benjamin M. Willis reviews observations from the poll results of his last three articles on controlled foreign corporation status and asks readers to choose one of four topics he can address in upcoming articles.
In news analysis, Joseph J. Thorndike argues that attempting to limit the influence of money in politics is complicated and uncertain, and that making rich people less rich might make things better or could just as easily make them worse.
In this installment of The SALT Box, Bland considers the ongoing debate over universal health care, as she explains the United States has the highest health care costs of all the industrialized countries in the world, yet the system itself ranks an appalling 28th in the quality of its health care, below almost all other wealthy countries.
In Tax History, Joseph J. Thorndike examines a moment in American history when a federal inheritance tax almost became a reality, and argues that the episode is a timely reminder that inheritance taxes have some durable appeal.
In news analysis, Benjamin M. Willis argues that the IRS incorrectly concluded that a domestic shareholder held all of a foreign corporation’s voting power and thus incorrectly treated the foreign corporation as a controlled foreign corporation.
Nana Ama Sarfo looks at suggested approaches to the OECD’s pillar 1 carve out issue, and contends that stakeholders may see a very different proposal emerge in response to commentator responses.
In news analysis, Marie Sapirie says the writers of the final Opportunity Zone regulations deserve commendation for delivering the package before the end of the year.
In economic analysis, Martin A. Sullivan questions whether the OECD’s GLOBE proposal will benefit U.S. multinationals more than the previous global intangible low-taxed income.
Carrie Elliot compares the status and priorities of the 2018-2019 priority guidance plan to the 2018-2019 priority guidance plan, and speculates on guidance to be released in 2020.
In news analysis, Marie Sapirie argues that while there are several congressional plans to fix the problems with the Opportunity Zone regime, it's up to Treasury to bring the regime back into reality.