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.
Carrie Brandon Elliot describes the new foreign tax credit limitation expense allocation and apportionment proposed regulations — including the role of new sections 951A (global intangible low-taxed income) and 245A (participation exemption).
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.
Carrie Brandon Elliot describes how the proposed regs related to section 163(j) seek to help taxpayers avoid mismatches and double-counting.
In news analysis, Nana Ama Sarfo reviews arguments explaining why GILTI design flaws have created stumbling blocks for taxpayers and practitioners alike.
Martin A. Sullivan argues that when it comes to the future of international income taxation, all roads lead to a minimum tax.
Marie Sapirie discusses cost-benefit analyses and evaluates how the IRS and Treasury have approached them so far in proposed and final regulations for Tax Cuts and Jobs Act implementation.
In news analysis, Carrie Brandon Elliot reviews how the new hybrid proposed regulations solve some, but not all, of the well-known problems related to dual consolidated losses.
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.
Robert Goulder examines the use of knowledge-sharing programs among national revenue bodies, as exemplified by the group Tax Inspectors Without Borders.