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Special Reports

Long form, detailed reports where federal, state and local, and international Tax Notes contributors tackle a wide range of topics including various tax laws, policies, and guidance.

In this report, Jasper L. Cummings, Jr., analyzes the statutory language of the new corporate alternative minimum tax, and he argues that guidance will likely change the statute’s words and be especially welcomed by the U.S. subsidiaries of foreign parents that are scrambling to determine the tax's applicability in 2023.
Ruth Mason explains how the global anti-base-erosion rules induce cooperation by states, and how the proposal to enact those rules via a directive in the European Union undermines that inducement to cooperate.
Fadi Shaheen argues that while two U.S. courts reached the desirable policy result in the Whirlpool case, their conclusion that the foreign base company sales income branch rule applies not only to sales branches but also to manufacturing branches is inconsistent with the statutory text.