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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.