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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.

Allison Christians considers the intricate design of the OECD's global anti-base-erosion regime, how it encourages countries to respond even if they choose not to adopt the GLOBE rules, and why a 15 percent minimum tax rate doesn't really mean 15 percent.
Larissa Neumann and Julia Ushakova-Stein examine the latest developments in the Whirlpool, Mann Construction, and Aptargroup cases; various OECD updates, including the global anti-base-erosion model rules, as well as the draft rules and the public consultation on nexus and revenue sourcing; comments on the final foreign tax credit regulations; IRS letter rulings on a qualified electing fund election, obligations in registered form, and a cross-border restructuring; and updates to the 2021-2022 priority guidance plan.

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