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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.

Jeffrey E. Moeller examines the source of the substantial rights rule in the regulations under section 41 and argues that the rule has been misinterpreted to deny the research credit to custom producers and
developers — the very type of taxpayer Congress intended to target.
Karl A. Frieden and Stephanie T. Do with the Council On State Taxation explain why the adoption of state-level digital services taxes that mirror European DSTs represents a solution in search of a problem that generally does not exist at the state level: the absence of economic nexus and market sourcing principles
to address the unique challenges of digital business models.
Annette Nellen reviews several issues and recommendations included in the most recent report of the IRS national taxpayer advocate submitted to Congress and adds observations about when these issues and recommendations would have implications, including benefits, for state tax systems.