Tax Notes State is an annual subscription to a weekly print or online magazine featuring expert commentary, analysis, and special reports on state tax issues.

- In-depth coverage of the latest tax decisions from the U.S. Supreme Court and state supreme and appellate courts - Cutting-edge special reports and insightful commentary from tax experts like Tax Analysts' own Billy Hamilton - Administrative rulings and regulations from all state revenue departments - Legislation from all 50 states and the District of Columbia - Full text and PDFs of the original source documents for legislation, court decisions, administrative rulings, and regulations

production

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Tax Notes State

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Tax Notes Today International is an annual subscription to daily online coverage featuring international news and analysis, including primary source documents.

- Daily online coverage featuring international news and analysis, including primary source documents - Includes FATCA Expert, Transfer Pricing Expert, and BEPS Expert &mdash; three robust one-stop shops for everything you need, from hard hitting analysis to in-depth commentary, with handy quick reference guides - Daily customizable emails on the topics you want

 Tax Notes Today International 

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Tax Notes Transfer Pricing Center is an annual subscription to a comprehensive online research tool featuring OECD, U.S., and international transfer pricing rules, updated in real time. The Transfer Pricing Center features daily transfer pricing news and long-form analysis articles written by transfer pricing experts from around the world.

- Unique comparison table offers a quick reference for transfer pricing terminology and concepts, mapping the OECD guidelines to the U.S. regulations 
- Comprehensive and searchable topic indexes linked directly to the OECD and U.S. guidance
- Official OECD guidance on transfer pricing, profit attribution, mutual agreement procedures, country-by-country reporting, and relevant articles of the OECD model tax convention
- Official U.S. statutes, regulations, and administrative guidance on transfer pricing
- Official transfer pricing guidance from the United Nations and other multilateral bodies
- Court opinions and key filings, related cases, and applicable regulations for major U.S. transfer pricing cases
- Transfer pricing guidance and court decisions for select jurisdictions worldwide
- The latest transfer pricing news and commentary from Tax Notes reporters and international tax experts

Tax Notes Transfer Pricing Center

Tax Notes Audit Insight is an annual subscription to audit training materials and sophisticated annotation tools. We've collected hard-to-find audit manuals from many states (and a few multistate organizations) to help you find guidance on the rules and procedures you need to stay tax compliant. These training materials include audit manuals for [corporate income tax](/document-list/tax-topics/corporate-taxation/corporate-taxation), [sales and use tax](/document-list/tax-topics/sales-and-use-taxation/sales-and-use-taxation), [income tax](/document-list/tax-topics/income/income), [property tax](/document-list/tax-topics/tax-types/property-taxation), and more. With the individual state subscription, you will have access to every audit manual we have been able to procure for your selected state, including any supplementary materials and updates to manuals as they are released.

**Included in your subscription:**
- Newly created table of contents for easy navigation
- Comparison tool to view any two documents side-by-side
- Search through your selected document(s) for any term, including simultaneous search in comparison view
- Add annotations to any document, including highlights and notes
- Create custom tags to categorize your notes
- Easily filter, sort, and share your notes
- Tax audit news for the state(s) of your choosing

**Details**
- Alaska
  - Fisheries Resource Landing Tax Audit Plan
  - Performing an Audit for Corporate Income Tax
- Arizona
  - Transaction Privilege Tax Audit Section General Audit Manual
- Arkansas
  - Audit Guidelines
- California
  - 2019 Multistate Audit Technique Manual
  - 2019 Residency and Sourcing Technical Manual
  - Audit Manual
  - Compliance Policy and Procedures Manual
  - Manual of Audit Procedures
  - Manual of Audit Procedures, Revised
  - Multistate Audit Technique Manual
  - Residency &amp; Sourcing Technical Manual
  - Sales and Use Tax Audit Manual
- Colorado
  - All Tax Audit Program
- Connecticut
  - Audit and Compliance Division — Field Audit Documentation Standards Manual
  - Bankruptcy Procedures
  - Combined Unitary Corporation Business Tax Presentation
  - Compliance Manual
  - Connecticut Corporation Business Tax Training Presentations
  - Connecticut Partnership and S Corporation Training Manual
  - Corporation Business Tax Credits Training Presentation
  - Corporation Tax Manual
  - Income Tax Training: Auditing Schedule C/Small Businesses Presentation
  - Income Tax Withholding Training Manual
  - Quick Start User Guide for: Sales and Use Tax Research
  - Sales and Use Tax Field Audit Referral Selection and Assignment Guidelines
- District of Columbia
  - Audit Division Financial Policies and Procedures Manual
- Florida
  - Sales and Use Tax for Auditors
- Georgia
  - Audit Training Manual
- Hawaii
  - Field Audit Manual
  - Office Audit Manual
- Idaho
  - Audit Workpapers
  - CP 2000 Manual (2019)
  - Collection Compliance Manual (2020)
  - Excise &amp; Sales Tax Unit Procedures Manual (2017)
  - FTRF Auditor Manual (2019)
  - Financial Technician — Desk Audit Manual (2016)
  - Income Tax Audit Manual
  - Intrastate Income Tax Audit Manual (2020)
  - Multistate Income Tax Audit Manual
  - Real Property Unit Procedures Manual
  - Residency Audit Manual (2020)
  - Sales Tax Auditor Manual (2019)
  - Taxation of Aliens Resource Manual (2019)
  - Withholding Manual | 2013 &amp; Forward
- Illinois
  - Audit Manual, Chapters 01 &amp; 02: General Audit Information
  - Audit Manual, Chapters 05 through 19: Sales Tax Audits
  - Audit Manual, Chapters 20 through 49: Income Tax Audits
  - Audit Manual, Chapters 60 &amp; 61: Miscellaneous Taxes
- Indiana
  - Audit Manual
  - Audit Manual (2020)
- International Fuel Tax Agreement
  - Procedures Manual
  - Audit Manual, 1996-2016
  - Audit Manual, 2017
- Kansas
  - Audit Training Manual for Mineral Severance Tax
  - Corporate Income Tax Auditor Training Manual
  - Corporate Income Tax Policy Manual
  - Corporate Income Tax Policy Manual, Revised
  - Sales/Use Tax Audit Guide
  - Statement on Standards for Attestation Engagements
- Kentucky
  - Audit Review Presentation
  - Basic Federal and Kentucky Individual Income Tax
  - Checklist: How to Conduct a Corporate Audit
  - Computer Assisted Audit Program Guidance
  - Computer Assisted Audit Program Responsibility Guidelines and Selection FAQs
  - Corporate Field Audit Techniques
  - Electronic Data Questionnaire and Audit Guidelines
  - Kentucky Individual Income Tax, 2014 Updates Presentation
  - Kentucky Inheritance Tax Manual
  - Partnerships
  - Partnerships and Pass-Through Entities
  - Personal Property Tax Manual 2010
  - Property Tax Non-Filer Compliance Refresher
  - Sales and Use Tax Manual
  - Severance Tax Training Presentation
- Louisiana
  - Corporation Income and Franchise Tax Auditing Training
  - Gasoline and Special Fuels Supplier Tax Audit Manual
  - Introductory Sales Tax Class Manual
- Maryland
  - Field Audit Section Procedures Manual
- Massachusetts
  - Field Audit Manual
  - Field Audit Procedures Manual (2019)
- Michigan
  - Audit Sampling Manual
  - Audit Standards for Field Audits
  - Contractor Manual
  - Industrial Processing Manual
  - Other Deductions Manual
- Minnesota
  - Auditor/Treasurer Manual, Property Tax Administration
  - Corporate Franchise Manual
  - Partnership Audit Manual
  - S Corporation Manual
  - Sales and Use Tax Operational Procedure Manual
- Missouri
  - Audit Guidelines
  - Audit Training and Reference Tools
  - Computer Training
- Montana
  - Field Audit Policy Manual
- Multistate Tax Commission
  - Income &amp; Franchise Tax Audit Manual (2020)
  - Income &amp; Franchise Tax Audit Manual
  - Sales and Use Tax Audit Manual (2021)
  - Sampling Policy &amp; Guideline Manual
- Nebraska
  - Audit Manual
- Nevada
  - Audit Manual
- New Jersey
  - Manual of Audit Procedures
  - NJ Manual of Audit Procedures (2021)
- New Mexico
  - General Audit Manual
  - General Audit Manual (2020)
  - Corporate Income Tax Audit Manual
- New York
  - Corporation Tax Audit Guidelines
  - Estate, Cigarette, and Alcoholic Beverage Tax
  - Fraud Audit Guidelines
  - Income Tax Audit Guidelines
  - Nonresident Audit Guidelines
  - Sales and Use Tax Audit Guidelines
- New York City
  - General Corporation Tax Training Manual
  - Utility Tax Manual
- North Carolina
  - Audit Report Procedures
  - Auditing for State Tax Purposes
  - Individual Income Tax Training
  - Interest, Penalties, and Payments
  - Personal Property Audit Seminar Manual
  - Residency
  - Sales and Use Tax
  - Sales and Use Tax Basics — General Procedures
  - Specific Applications of Tax
  - The Examination and Various Audit Methodologies
- North Dakota
  - Sales and Special Taxes Division's Field Audit Manual
- Ohio
  - Audit Processes
  - International Fuel Tax Agreement Training Materials
  - International Registration Plan Audit Training Materials
  - Passthrough Entity Tax Presentation
- Oklahoma
  - Auditing the Oklahoma Capital Gain Deduction
  - Compliance Division Field Audit Section Guidelines Manual
  - Corporate Income Tax Section
  - Exclusions and Credits
  - Procedures for Reviewing/Auditing Oklahoma Credits on Individual Amended Returns
- Oregon
  - Audit Manual
  - Business Use of Home
  - Corporate Income Tax Training Materials and Presentations
  - Corporation Section Audit Manual
  - Oregon Filing Requirements
  - Oregon Personal Income Tax Training Materials
  - Passthrough Entity Taxation Training Materials
  - Personal Income Tax Audit Manual
- Pennsylvania
  - Corporation Tax Audit Manual
  - Liquid Fuels and Fuels Tax Audit Manual
  - Sales and Use Tax Audit Manual
- Rhode Island
  - Field Audit Services Audit Manual
- Texas
  - Auditing Fundamentals
  - Sampling Manual
  - Audit Procedures for Cement Production Tax
  - Audit Procedures for Contractors and Repairmen
  - Audit Procedures for Convenience Stores
  - Audit Procedures for Grocery Stores
  - Audit Procedures for Hotel Occupancy Tax
  - Audit Procedures for Manufacturers
  - Audit Procedures for Oil and Gas Well Servicing
  - Audit Procedures for Utilities Gross Receipts Tax
  - Audit Procedures for Vessels
  - Audit Procedures for Enterprise Zones &amp; Qualified Hotel Projects
  - Mixed Beverage Gross Receipts and Sales Tax Manual
  - Motor Fuels Audit Procedures Manual — Chapter 162
  - Motor Fuels Audit Procedures Manual — Chapter 153
  - Motor Vehicle Tax Manual
  - Sulphur Production Manual
  - Audit and IFTA Software Procedures
  - Local Revenue Funds Manual
  - Well Servicing Tax Manual
  - Cigar &amp; Tobacco Products Tax Manual
  - Audit Procedures for Cigarette Tax
  - Audit Procedures for Telecommunications Taxes
- Vermont
  - Audit Best Practice and Resource Guide
  - Basics of Basis
  - Business and Corporate Intro Training
  - Establishment of Nexus
  - Life Cycle of an Audit — Income Taxes
  - Life Cycle of an Audit — Meals and Rooms
  - Life Cycle of an Audit — Miscellaneous Taxes
  - Life Cycle of an Audit — Sales and Use
  - Life Cycle of an Audit — Withholding Taxes
  - Standard Operating Procedure: Audit Referral
  - Vermont Meals and Rooms Tax — Overview
  - Vermont Sales and Use Tax — The Basics
- Virginia
  - Field Audit Guidelines
  - Field Collections Guide
- Washington
  - Auditor's Reference Manual
  - Managed Audit Guide
  - Random Sampling Program
  - Special Programs Auditor Desk Manual
  - Statistical Sampling Manual
- Wisconsin
  - Combined Reporting New Auditor Training Presentations
  - Individual Income Tax Auditor Training Materials
  - Overview of Field Auditing
  - Sales and Use Tax Law and Auditing
- Wyoming
  - Audit Division Tax Audit Procedures Manual — Bentonite
  - Audit Division Tax Audit Procedures Manual — Coal
  - Audit Division Tax Audit Procedures Manual — Oil &amp; Gas
  - Audit Division Tax Audit Procedures Manual — Trona
  - Audit Procedures Manual for Sales Use Tax, Lodging Tax, Fuel Tax, Corporate License Tax and Cigarette Tax
  - Excise Tax Division Audit Procedures Manual
  - State Royalty Audit Procedures Manual

Audit Insight: Individual States

Tax Notes Audit Insight is an annual subscription to audit training materials and sophisticated annotation tools. We've collected hard-to-find audit manuals from many states (and a few multistate organizations) to help you find guidance on the rules and procedures you need to stay tax compliant. These training materials include audit manuals for [corporate income tax](/document-list/tax-topics/corporate-taxation/corporate-taxation), [sales and use tax](/document-list/tax-topics/sales-and-use-taxation/sales-and-use-taxation), [income tax](/document-list/tax-topics/income/income), [property tax](/document-list/tax-topics/tax-types/property-taxation), and more. With the individual state subscription, you will have access to every audit manual we have been able to procure for your selected state, including any supplementary materials and updates to manuals as they are released.

**Included in your subscription:**
- Newly created table of contents for easy navigation
- Comparison tool to view any two documents side-by-side
- Search through your selected document(s) for any term, including simultaneous search in comparison view
- Add annotations to any document, including highlights and notes
- Create custom tags to categorize your notes
- Easily filter, sort, and share your notes
- Tax audit news for all available states

Audit Insight: All Available States

Tax Notes International is an annual subscription to a weekly print or online magazine featuring expert commentary, analysis, and special reports on international tax issues.

- Full coverage of FATCA news and analysis, including an always up-to-date IGA chart - Full coverage of transfer pricing issues, including OECD guidelines, U.N. manuals, and U.S. regulations - Cutting-edge special reports and insightful commentary from tax experts like Tax Analysts' own Martin Sullivan, Lee Sheppard, and Mindy Herzfeld

Tax Notes International

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BEPS Expert is an annual subscription to news, analysis, and insight regarding the final OECD reports and what they mean for international taxation.

- BEPS Expert features an easy-to-use reference table, including final OECD reports, comment letters, and original source documents &mdash; all grouped by action item for easy access. - Up-to-date feed of our compelling and insightful news and analysis on all things BEPS.

 BEPS Expert

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Exempt Organizations Expert is an annual subscription to news, analysis, and commentary on the latest issues affecting nonprofits, with primary source documents including full guidance from the IRS and Treasury.

- Daily news and analysis covering the tax implications of law changes and policy shifts for nonprofit organizations - IRS letter rulings and chief counsel advice, as well as news, correspondence, final regulations, information letters, and other documents from the IRS, including full text guidance - Congressional Research Service reports, congressional tax correspondence, and other congressional documents - Status reports on current exempt organization litigation

Exempt Organizations Expert 

Tax Notes Insurance Expert is an annual subscription to daily online news, analysis, and commentary on the latest issues in insurance taxation, with court opinions and documents from Congress and the IRS.

- Daily news and analysis covering the tax implications of law changes and policy shifts for insurance taxation - IRS letter rulings and chief counsel advice, as well as news, correspondence, final regulations, information letters, and other documents from the IRS, including full text guidance - Congressional Research Service reports, congressional tax correspondence, and other congressional documents - Status reports on current insurance tax litigation

Insurance Expert

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Tax Notes Federal is an annual subscription to a weekly print or online magazine featuring expert commentary, analysis, and special reports on federal tax issues.

- Coverage and analysis of federal tax law changes and policy shifts &mdash; often months before they happen - Cutting-edge special reports and insightful commentary from experts like Tax Analysts' own Martin Sullivan and Lee Sheppard - Full coverage of FATCA news and analysis, including an always up-to-date IGA chart - A vast collection of searchable source documents, including IRS regulations, the Internal Revenue Manual, Treasury decisions, and opinions from the U.S. Supreme Court, U.S. Tax Court, and many other district and appellate courts

Tax Notes Federal

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The Exempt Organization Tax Review is a monthly print and online summary of the latest issues affecting nonprofits, including the full text of guidance from the IRS and Treasury.

- News and analysis covering the tax implications of law changes and policy shifts for nonprofit organizations - IRS letter rulings and chief counsel advice, as well as news, correspondence, final regulations, information letters, and other documents from the IRS, including full text guidance - Congressional Research Service reports, congressional tax correspondence, and other congressional documents - Status reports on current exempt organization litigation

The Exempt Organization Tax Review 

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Tax Practice Expert is an annual subscription to a weekly update with news, analysis, and primary source documents related to federal taxation, intended for tax practitioners who are focused on individuals and small businesses.

- IRS Round Up section includes primary source IRS documents including news releases, fact sheets, announcements, procedures, rulings, actions on decisions, legal memoranda, technical assistance, chief counsel notices, and other documents - Court Round Up section contains primary source court documents, including court opinions from the Tax Court, district courts, and circuit courts - Special Topics section includes practice articles on federal tax issues when available.

Tax Practice Expert

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Tax Notes Today State is an annual subscription to daily online coverage of state and local tax news and analysis, including primary source documents and customized email alerts to bring you news as it happens.

- Daily state news and analysis, including primary source documents - Timely news for key developments affecting your clients' tax liabilities - Daily customizable emails on topics you want - Information on state tax amnesty programs, making it easy for practitioners to find up-to-date information and take advantage of short-term amnesty offers

Tax Notes Today State

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Tax Notes Today Global is an annual subscription to daily online coverage featuring international news and analysis, with additional multinational coverage from a U.S. perspective.

- Daily online coverage featuring international news and analysis, with additional multinational coverage from a U.S. perspective - Designed specifically for international tax professionals who need a full awareness of global tax issues - Includes FATCA Expert, Transfer Pricing Expert, and BEPS Expert &mdash; three complete one-stop shops for everything you need, from hard-hitting analysis to in-depth commentary, with handy quick reference guides - Daily customizable emails on the topics you want

 Tax Notes Today Global

Tax Notes Today Federal is an annual subscription to daily online coverage featuring federal news and analysis, including primary source documents and customized email alerts to bring you news as it happens.

- Online tax news and analysis supplemented with an in-depth library of current and archived documents - Access to <a href="../../../../../fatca-expert">[FATCA Expert](/fatca-expert)</a>, featuring the latest news, in-depth analysis, and an always up-to-date IGA chart - Searchable full-text documents from courts, Congress, and government agencies and departments, including congressional correspondence; Tax Court opinions; GAO reports; internal revenue bulletins; chief counsel advice; proposed, final, and temporary regulations; public comments on regulations; and Joint Committee on Taxation correspondence - Daily customizable emails focused on your choice of topics

Tax Notes Today Federal Individual Product Page

Tax Notes Today Federal

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Worldwide Tax Treaties is an annual subscription to online access of a comprehensive research tool featuring unparalleled coverage of international tax treaties, updated in real time.

- A database of more than 12,000 treaties, amending protocols, and similar documents, plus over 46,000 treaty-related documents and news stories - Worldwide Tax Summaries, a collaborative effort between Tax Notes and PwC featuring detailed country profiles continually updated by global PwC specialists - Helpful tools to directly compare both tax treaties and tax rates for every available jurisdiction

Worldwide Tax Treaties - Product Page

Tax Notes is proud to present a resource for practitioners wrestling with the Tax Cuts and Jobs Act. Contributing editor Carrie Brandon Elliot has written a collection of articles that offers a thorough explanation of topics such as foreign tax credits, subpart F, PFICs, hybrids, and the implications for partnerships and consolidated groups.

This collection contains the following articles:

- "The TCJA's Effect on Foreign Tax Credits"
- "How the TCJA Has Changed Subpart F"
- "The TCJA's Effect on PFICs and Controlled Foreign Corporations"
- "The TCJA and Capital Gains"
- "The TCJA and Indefinite Reinvestment Assertions"
- "The TCJA and U.S. Real Estate Investments by Foreign Persons"
- "The TCJA and Passive Income: Mixed Incentives"
- "The TCJA's New Revenue Recognition Timing Test"
- "The TCJA's Tax Accounting Challenges"
- "The TCJA's Fourth-Quarter Playbook for Filers"
- "The TCJA's Effects on Oil and Gas Investments"
- "The TCJA's Bargain With Insurance Companies"
- "The TCJA and Partnerships"
- "TCJA Tax Rate Increases to Begin in 2019"
- "The TCJA Brings Big Changes to Tax Accounting"
- "Reducing TCJA Accounting Distortions"
- "New TCJA-Related Regs Ease Double Counting and Income Mismatches"
- "TCJA and Effectively Connected Income Deduction Limits"
- "The TCJA and New FTC Limitation Rules"
- "How GILTI Discourages Research in the United States"
- "Expanding Hybrid Deduction Accounts to GILTI and Subpart F"
- "How Imported Mismatch Payment Rules Can Create Double Taxation"
- "TCJA Hybrid Regulations: Overreach or Underdone?"
- "Extending TCJA Section 267A to Reverse Hybrids"
- "Stretching Interest Disallowance Applicability in Section 267A"
- "Navigating TCJA Foreign Tax Credit Limitations"
- "How Section 245A Temporary Regs Limit Dividends Received Deductions, Part 1"
- "How Section 245A Temporary Regs Limit Dividends Received Deductions, Part 2"
- "How Sections 245A and 964(e)(4) Coordinate Treatment of Dividends"
- "Proposed New Regs Allow GILTI Exclusion for CFC High-Taxed Income"
- "Election to Consolidate Can Affect Transition Tax Liability"
- "Consolidated Groups Face Challenges From Proposed 163(j) Regs"
- "Consolidated Groups Wrestling With the BEAT"
- "Consolidated Group Members Become Single Under GILTI"
- "Consolidated Groups Weigh GILTI Effect on Basis Adjustments"
- "Consolidated Groups Seek Deductions Under Proposed FDII and GILTI Regs"
- "Consolidated Groups Still Facing Hybrid and DCL Problems"
- "A New Hybrid Approach for Partnerships in GILTI and Subpart F Regs"
- "Reducing GILTI Inclusion by Capitalizing or Apportioning Depreciation"
- "Using an Aggregate Approach to Determine Partnership QBAI"
- "Antiavoidance Rules Thwart Reduced GILTI Inclusions"
- "How Qualified Interest Income and Expense Can Affect GILTI Inclusions"
- "Inventory Your Cost of Goods Sold to Minimize the BEAT"
- "Preventing Double Nontaxation: Subpart F and GILTI Coordination"
- "Clarifying TCJA Insurance Provisions in Proposed PFIC Regs"
- "Proposed BEAT Regs Clarify Aggregate Group Rules"
- "Beat the BEAT: Waiving Base Erosion Deductions"
- "Beat the BEAT, Part 2: Partnership Antiabuse"
- "Tweaking Old Expense Rules for New TCJA Realities"
- "New Regs Address High-Taxed Exceptions When Foreign Tax Reduced"
- "Navigating New Foreign Income Tax Allocation and Apportionment Regs"
- "Proposed Regs Allow Some Loss Recapture to Affect FTC Limitation"
- "Clarifying the Consolidated FTC Limitation Computation"
- "Clarifying Subpart F and GILTI Inclusions for Indirect and Deemed Paid Taxes"
- "Regs Increase Fractions Limiting FTC Deemed Paid Taxes"
- "New Inclusion Requirements for Deemed Paid Tax Calculations"
- "Regs Allow FTC Limitation Adjustments For GILTI Distributions"
- "How Disregarded Transactions Can Alter the FTC Limitation"
- "Section 904 Regs’ Further Clarify Foreign Branch Income Category"
- "New GILTI High-Tax Regs Introduce Tested Units"
- "New GILTI High-Tax Regs Address Disregarded Payments"
- "New Regs Address High-Tax GILTI Election"
- "Proposed Regs Modify Effective Foreign Tax Rate Calculation"
- "Proposed High-Tax Regs Introduce New Subpart F and GILTI Concepts"
- "Proposed High-Tax Regs Introduce New Documentation Requirements"
- "Proposed Regs Allow Group Interest Deduction Limitation"
- "Proposed Regs Give and Take: Safe Harbor and Antiavoidance Rules"
- "Proposed Regs Clarify 2019, 2020 COVID-19-Related Interest Rules"
- "Proposed Regs Modify Interest Limitation Formula for Effectively Connected Income"
- "Final Regs Address Interest Expense Limitation for Partnerships"
- "Final Regs Provide 11 Steps for Partnerships With Interest Limitation"
- "Partnership Interest Calculation Includes Conditional Eighth Step"
- "Proposed Regs Clarify Interest Rules for Tiered Partnerships"
- "Proposed Regs Clarify Conversion Events for Tiered Partnerships"
- "Proposed Regs Clarify Dispositions of Tiered Partnership Interests"
- "Final Regs Limit Disqualified Basis Reduction"
- "Final Regs Address Multiple Extraordinary Disposition Accounts"
- "Addressing Exchanged Basis Property and Duplicate Disqualified Basis"
- "Final Regs Lay Ground Rules for Section 1446(f) Withholding"
- "Final Regs Allow Six Exceptions to Section 1446(f) Withholding"
- "Final Regs Allow Adjustments to Section 1446(f) Withholding"
- "Final Regs Clarify Partnership Withholding Under Section 1446(f)(4)"
- "Final Regs Clarify Withholding for Publicly Traded Partnerships"
- "Final Regs Offer Five Exceptions to PTP Withholding"
- "Final Regs Clarify PTP Withholding on Distributions"

Products - Special Issues - The Tax Cuts and Jobs Act: A Practitioner's Resource

Tax Notes provides a special supplement on developments in federal, state, and international taxation relevant to the May 2019 American Bar Association Section of Taxation meeting in Washington. Topics include taxation of the digital economy, treaty shopping and abuse, and whether the Tax Cuts and Jobs Act encourages incorporation.

This collection contains the following articles:

- "OECD Weighing Extensive Input on Digital Economy Tax Proposals"
- "TCJA Brings Big Changes to Tax Accounting"
- "The Future of Transfer Pricing"
- "Review of and Insights on the IRS Transfer Pricing Examination Process"
- "BEPS Aftermath: Mechanisms to Curtail Treaty Shopping and Abuse"
- "The Arm's-Length Standard Enters Its Second Century"
- "Wayfair's Warning for Inappropriate Tax Planning"
- "The Tables Turn: A State Asserts Unconstitutionality of a Tax on Passthrough Owners"
- "Burying New York's ‘Only Reasonable Construction? Standard"
- "Should States Embrace GILTI?"
- "Reflections on 55 Years of Tax Practice"
- "Failure to Innovate: Tax Compliance and the Gig Economy Workforce"
- "The Outer Bounds of Discretionary Sentencing in Criminal Tax Cases"
- "Tax Accounting Meets International Tax"
- "The Summons Interview: Potted Plant or Rambo Approach?"
- "Interest Deduction Limitation: Matters of Principle or Principal?"
- "The TCJA and the Questionable Incentive to Incorporate"

Products - Special Issues - State of Play: Developments in Federal, State, and International Taxation

It's no exaggeration to say that we are living through one of the most exciting and important periods in the history of tax. The challenges presented by the Tax Cuts and Jobs Act, the Wayfair decision, and Brexit will affect tax administration at the federal, state, and international levels for years to come. Tax Notes is proud to offer this collection of articles written by noted experts in the field and carefully compiled by our editors in chief. It is intended to provide readers with thoughtful analyses of the most pressing issues of the day.

This collection contains the following articles: - "The New Non-Territorial U.S. International Tax System" - "Post-2017 Foreign M&amp;A" - "Reassessing the Beloved Double Irish Structure in Light of GILTI" - "The DiRTTy and the GILTI" - "The Base Expansion Arbitrary Tax" - "Reassessing the Beloved Double Irish Structure in Light of FDII" - "The Nitty-Gritty of FDII" - "The TCJA Treaty Conundrum" - "Why (and How) States Should Tax the Repatriation" - "Proposed 199A Regulations: Three Big Questions Remain" - "Simplifying the Business Interest Expense Rules for Passthroughs" - "Moving Past a TCJA State of Bewilderment" - "State Corporate Income Tax Consequences of Federal Tax Reform" - "Congress Should Sprinkle Some SALT on the Federal Courts" - "The Final Tax Reform Act: SALT Implications" - "A Change of Landscape" - "The Strange Death of Stare Decisis" - "26 Things You May Not Know About the Wayfair Decision" - "The International Implications of Wayfair" - "Sales Taxes in a Post-Wayfair, Post-Kennedy World" - "Comments on the EU's Proposed Indirect Digital Services Tax" - "Getting Ready for the EU's Anti-Tax-Avoidance Directive" - "The Tax Consequences of Brexit"

Products - Special Issues - TCJA, Wayfair, and Beyond

We are proud to present a special edition of Tax Notes International for IFA 2018 Seoul. We have compiled a selection of top articles on the Asia-Pacific region outlining countries' efforts to modernize their tax systems to remain competitive in the global economy. Among the highlights are Yasutaka Nishikori and Hidenori Sato's insights on Japan's CFC updates, Abe Zhao's review of China's new beneficial ownership rules, and Ajitesh Kir's assessment of India's goods and services tax, one year after its enactment.

This collection contains the following articles: - "China's General Antiavoidance Rule and Its Commitment to the Exchange of Information" - "24 Years Later &mdash; China Finally Centralizes Its Tax Administration" - "China's New Beneficial Ownership Rules Create Tax Saving Opportunities" - "Japan Upgrades Its CFC Regime" - "Moving to Territorial: Lessons From Japan" - "Simple and Competitive: Proposed Tax Measures in Hong Kong" - "Tax Trends and Tax Reforms in the Developing East Asia and Pacific Region" - "Have Developing Countries Declared Open Season on Mining Companies?" - "The Biggest Tax Reform Since Independence: Has the GST Improved the Ease of Doing Business in India?" - "Recent Korean Tax Developments: Increase in Corporate Income Tax Rate and Listing on EU Blacklist"

Products - Special Issues - Asia-Pacific Tax Trends, Reforms, and Developments

Tax Analysts and the IBFD are pleased to present a collection of essays on the challenges of taxing the digital economy. Each contribution stands alone as an individual piece of analysis. In the aggregate, the body of work illustrates the complex landscape facing policymakers today.

This collection contains the following articles:

- "Introduction: A Stress-Test for the International Consensus"
- "Digital Permanent Establishment and Digital Equalization Taxes"
- "A Review of Comments on the Tax Challenges of the Digital Economy"
- "Finding Middle Ground Over Unilateral Digital Taxation"
- "Permanent Establishment and the Digital Economy"
- "Taxation of the Sharing Economy: Recurring Issues"
- "Taxing the New Gig Economy"
- "Argentina's Journey to a Digital VAT"
- "The Future of the Permanent Establishment Concept"
- "Managing EU VAT Risks for Platform Business Models"
- "Some Comments on the Attribution of Profits to the Digital Permanent Establishment"
- "Addressing the Tax Challenges of the Digitalization of the Economy — A Possible Answer in the Proper Application of the Transfer Pricing Rules?"
- "Digital Revolution. Tax Revolution?"
- "An Analysis of 'Google Taxes' in the Context of Action 7 of the OECD/G20 Base Erosion and Profit Shifting Initiative"
- "Taxation of Cloud Computing in Brazil: Legal and Judicial Uncertainties"
- "Recent Developments in Brazil Regarding the Indirect Taxation of Services in the Digital Economy"
- "Japanese Tax Reforms Square Up to BEPS Action 1 to Tackle Tax Challenges of the Growing Digital Economy"

Products - Special Issues - Navigating the Tax Challenges of the Digital Economy

Tax Notes is proud to offer searchable, electronic versions of the leading treatise on securitizations, Federal Income Taxation of Securitization Transactions and Related Topics (Fifth Edition 2018), by James M. Peaslee and David Z. Nirenberg. The book, which has been updated to reflect TCJA and other developments in law and practice since the last edition, uses securitizations as a framework for addressing a wide range of topics of interest in a financially oriented tax practice. Hard copies of the book may be purchased <a title="Purchase Hard Copy" href="http://a.co/gfULQkD" target="_blank" rel="noopener">here</a>.

<div>This treatise focuses on the following topics:
<ul>
<li>Chapter 1 &ndash; Tax Issues in Securitization Transactions</li>
<li>Chapter 2 &ndash; Types of Asset-Backed Securities</li>
<li>Chapter 3 &ndash; Sale/Financing and Debt/Equity Issues</li>
<li>Chapter 4 &ndash; Classification of Issuers Other Than REMICs</li>
<li>Chapter 5 &ndash; Trusts Issuing Pass-Through Certificates Taxable as Grantor Trusts or Partnerships</li>
<li>Chapter 6 &ndash; Qualification and Taxation of REMICs</li>
<li>Chapter 7 &ndash; Definition of REMIC Regular Interest</li>
<li>Chapter 8 &ndash; Taxation of Holders of Asset-Backed Securities Taxable as Debt</li>
<li>Chapter 9 &ndash; Taxation of Holders of Equity Interests in Trust Issuers of Debt and REMIC Residual Interests</li>
<li>Chapter 10 &ndash; Taxation of Taxable Mortgage Pools and Holders of Equity Interests in Taxable Mortgage Pools</li>
<li>Chapter 11 &ndash; Special Rules for REITs, Tax-Exempt Organizations, Financial Institutions, and Securities Dealers</li>
<li>Chapter 12 &ndash; Taxation of Foreign Investors</li>
<li>Chapter 13 &ndash; Offshore Issuers</li>
<li>Chapter 14 &ndash; Legending and Information Reporting</li>
<li>Chapter 15 &ndash; Taxation of Sponsors</li>
<li>Chapter 16 &ndash; Tax Law Aggregation or Separation of Property Interests</li>
<li>Chapter 17 &ndash; Special Topics</li>
<li>Appendix A &ndash; State Tax Exemptions for REMICs</li>
<li>Appendix B &ndash; Code Sections, Regulations, and IRS Forms Worth Knowing About</li>
<li>Appendix C &ndash; CDO Trade or Business Guidelines</li>
</ul>
</div>

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