TCJA, Wayfair, and Beyond


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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&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"