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Featured Analysis

Carrie Brandon Elliot reviews how the unintended consequences of hybrid regulations can reflect overreach as applied to notional interest deductions and group relief, and incompleteness as applied to inclusions under the global intangible low-taxed income and subpart F regimes.
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.