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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 specialized topics including various tax laws, policies, and guidance.

Brian Hamer argues that recent decisions by Illinois’s Independent Tax Tribunal describe a troubling example of how some multinational taxpayers cross the line circumscribing responsible corporate conduct and show how legislative compromises made in the 1980s continue to threaten state tax bases.
Amy F. Nogid of Alston & Bird LLP continues her discussion of SALT issues for foreign businesses operating in the United States, addressing worldwide combination, extraterritorial income, and apportionment, as well as potential restraints on the ability to collect tax judgments from non-U.S. entities.
John L. Harrington considers the additional taxing rights and enhanced dispute prevention and resolution measures that pillars 1 and 2 would provide, as well as dispute prevention and resolution measures that could result, focusing on the challenges of reconciling these new “tax certainty” provisions with the noncompulsory payment rules in the new U.S. foreign tax credit regulations.
Amy F. Nogid with Alston & Bird LLP discusses some of the rules to which non-U.S. businesses must abide, federal constitutional provisions that apply to non-U.S. businesses, threshold taxability issues, and quirky local taxes that routinely fall under the radar of foreign businesses.
J. Clifton Fleming Jr., Robert J. Peroni, and Stephen E. Shay explain that for U.S. corporations earning foreign-source active business income through controlled foreign corporations, pre-Tax Cuts and Jobs Act tax deferral planning is now largely obsolete and has been replaced with planning that centers on avoiding subpart F income and maximizing global intangible low-taxed income. They also explain that the low GILTI tax rates are a tax expenditure that fares poorly under cost-benefit analysis, even when taking into account the new U.S. corporate minimum tax and the possibility of modifications that would make the GILTI regime pillar 2 compliant.

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