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.
Anna Cronic and Brian J. Kirkell of RSM US LLP explore a recent decision holding that the Arkansas Department of Finance and Administration’s application of market-based sourcing to a remote service provider was an appropriate use of the state’s discretionary power under its alternative apportionment statutes.
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.
Naomita Yadav of Withersworldwide LLP examines California’s taxation of nonresident individuals and trusts.
Heydon Wardell-Burrus sets out a pillar 1 design proposal that leverages pillar 2 to reallocate taxing rights to market jurisdictions and avoid double taxation without requiring amendments to U.S. tax treaties.
Karl A. Frieden, Fredrick J. Nicely, and Priya D. Nair of the Council On State Taxation examine key issues regarding state sales taxation of digital commerce, focusing on the absence of sales tax exemptions in most states for purchases of software and digital products by businesses.
Jennifer Ray and Dina Wiesen argue that most partnership divisions in which taxpayers attempt to separate business lines, assets, or partners ought to be analyzed as happening in a bubble.
Ted Tourian examines California’s FTB Legal Ruling 2021-01, which discusses situations in which a passthrough entity serves as a holding entity of another passthrough entity.
Heydon Wardell-Burrus considers whether the qualified domestic minimum top-up tax in the OECD’s pillar 2 model rules should be treated as creditable from a policy perspective.
Stephen L. Curtis breaks down eBay’s cost-sharing arrangement and explains how corporate taxpayers have been able to exploit the cost-sharing regulations to shift billions in U.S. profits offshore with little or no IRS detection or enforcement.
Jeffrey A. Friedman and Cyavash N. Ahmadi of Eversheds Sutherland (US) LLP argue that based on its recent history of costly and protracted litigation, New York’s application of the False Claims Act to tax matters should be reformed or eliminated.
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