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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.

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.
Marie Sapirie examines the revamped clean vehicle credit in the Inflation Reduction Act, arguing that the new requirements will make the credit harder to qualify for in the short term, but that they’ve been tightened to encourage technological development of electric vehicles.
Senate Republican Whip John Thune of South Dakota describes his actions to remove a Democratic provision in the Inflation Reduction Act that would have modified the aggregation rules to the corporate minimum tax, thereby impacting small businesses owned by private equity funds and partnerships.
Reuven S. Avi-Yonah and Bret Wells argue that the corporate alternative minimum tax proposed in the Inflation Reduction Act of 2022 would put the United States in a better position than current law, and arguably even better than would a tax reform package that included a conforming global intangible low-taxed income regime but no book-based corporate minimum tax.
In this installment of The SALT Box, Roxanne Bland considers New York ex. rel. American Advisory Services LLC v. Egon Zehnder International Inc. and whether the New York False Claims Act or Rule 24 of the Federal Rules of Civil Procedure controls a state’s motion to intervene.