Tax Notes logo

Click here to see operators for terms and connectors searching.

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.

Calvin H. Johnson supplements his argument that interest deductions should be limited to a ceiling of interest rate times adjusted basis, and he clarifies when the remedy is inappropriate, that capitalization doesn’t remedy the negative tax harm, and that all exempt income should be subtracted from adjusted basis for the ceiling calculation.
Nana Ama Sarfo reviews upcoming priority actions for the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, including the use of treaty-exchanged tax information to fight illicit financial flows.
Mitchell A. Kane argues that the Supreme Court should not grant certiorari in Oakbrook Land Holdings LLC v. Commissioner, a conservation easement case in which the Sixth Circuit upheld the validity of a Treasury regulation regarding the agreed distribution of proceeds following state law extinguishment of the easement.
Reuven S. Avi-Yonah examines the post-Mayo revolution that has occurred in the application of the Administrative Procedure Act to tax regulations, and he offers two solutions to the problem of using notice and comment for those regs.