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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.

Congress recently passed the Inflation Reduction Act of 2022, which includes climate incentives and healthcare provisions, along with a 15 percent corporate minimum tax. What are the tax implications of the act, particularly of the minimum tax? In a September 22 "Taxing Issues" webinar, panelists Kimberly Clausing of UCLA School of Law, Rohit Kumar of PwC, and Watson McLeish of the U.S. Chamber of Commerce shared different perspectives on the new law.
Lorraine Eden considers the revised amount A concept in the OECD progress report, arguing that it is more flawed than its predecessor, increases the risks of double taxation, and would allow tax administrations and in-scope multinationals to game the calculation.
Reuven S. Avi-Yonah looks at the Tax Court’s recent Medtronic II decision and considers how the new corporate alternate minimum tax may provide a solution to the problem of adjudicating transfer pricing in the absence of comparables.
Stephanie Hunter McMahon of the University of Cincinnati College of Law advocates for Congress to enact when possible, and otherwise to push for, an expansion of the social safety net for prison labor on terms consistent with that for non-incarcerated workers, taking into account the prison context.
Benjamin Alarie and Kim Condon use machine-learning models to evaluate the strength of the IRS's argument that the Tax Court in Mylan erred in holding that a generic drug manufacturer is not required to capitalize litigation expenses incurred in defending against patent infringement suits and instead may deduct them as ordinary and necessary business expenses.
In this installment of The SALT Box, Roxanne Bland discusses inventory taxes at the state and local level with Tax Analysts' very own chief economist, Martin Sullivan.