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.
In economic analysis, Lee A. Sheppard and Martin A. Sullivan analyze Sen. Elizabeth Warren’s proposed tax increases to pay for her Medicare for All plan, with special attention paid to her employer Medicare contribution.
In Tax History, Joseph J. Thorndike reviews Emmanuel Saez and Gabriel Zucman’s new book and argue that while the authors provide good historical interpretation while making their case for taxing wealth, they fail to identify the conditions that will lead to progressive tax change in the future.
Carrie Brandon Elliot reviews new proposed regulations under section 861 that govern classification of income from digital content and cloud transactions that could affect foreign tax credits, subpart F, BEAT, FDII, and GILTI.
Mindy Herzfeld discusses similarities between proposals from the OECD and Sen. Elizabeth Warren, D-Mass., for a tax base that relies on earnings reported on financial statements and explains why using that base is less than optimal.
In economic analysis, Martin A. Sullivan examines Emmanuel Saez and Gabriel Zucman’s new book on taxing the super wealthy and argues that while most Americans can safely ignore the possibility of a U.S. wealth tax, the political and economic developments that are putting it in the news should not be ignored.
Nana Ama Sarfo looks at growing controversy over how certain tax credits and accumulated depreciation will be treated after India's corporate tax update.
In news analysis, Benjamin M. Willis examines Moore, a recent case challenging the constitutionality of the repatriation tax in section 965.
In this winning entry in Tax Notes’ annual student writing competition, Benjamin M. Satterthwaite proposes a transfer pricing framework for unique intangibles that integrates the economic fundamentals of John Nash’s bargaining theory with the “realistic alternatives” language of amended sections 367(d) and 482.
In news analysis, Mindy Herzfeld examines the French digital services tax that’s expected to primarily affect large U.S. tech companies and the various options the United States has to combat it.
Nana Ama Sarfo looks at how adoption of comments on the Treasury Department's proposed partnership withholding regulations might substantially expand the regime.