State of Play: Developments in Federal, State, and International Taxation


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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 Yorkʹs ‘Only Reasonable Constructionʹ 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