Tax Analysts

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Special Reports

Congress inserted several provisions into the Tax Cuts and Jobs Act, arguably intended to address corporate arrangements when federal taxable income (on which the state relies) is disconnected from profitability, perhaps most significantly a tax on global intangible low-taxed income.  In this edition of Board Briefs, I asked State Tax Notes board members to weigh in on whether states should embrace GITI.
Ilaria Palieri examines the issue of fiscal state aid, considering the recent cases that the European Commission has brought involving tax rulings for multinational enterprises in light of the existing case law from the Court of Justice of the European Union, and suggests that MNEs pay close attention to the topic, especially the questions of advantage and selectivity, noting the importance of determining a reference system and identifying the objective of that system in a proper state aid analysis.