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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.

Marsha Laine Dungog, Jennifer S. Silvius, and Jonathan Garbutt consider the use of Canadian registered plans (the Canadian tax-free savings account and the retirement compensation arrangement) by U.S. persons working in Canada and whether those plans should be treated as foreign trusts in the United States, arguing that the United States should provide clear administrative guidance on the U.S. tax treatment of such plans.
Amy F. Nogid and Tiffany Li Qu with Alston & Bird LLP discuss the potential impact of state business qualification on jurisdiction, provide some background on jurisdictional standards, and analyze a case on the issue pending before the U.S. Supreme Court.
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.

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