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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.

James P. Fuller, Larissa Neumann, and Julia Ushakova-Stein examine recent OECD developments, including the updated transfer pricing guidelines and the pillar 2 model rules; comments on the corporate and international tax provisions of the stalled Build Back Better Act; IRS practice units on the base erosion and antiabuse tax and flow-through foreign tax credits; and an IRS letter ruling allowing a domestic publicly traded company’s merger costs to be hedged.
Hale E. Sheppard examines a recent conservation easement donation dispute, Little Horse Creek Property, and explains several taxpayer-favorable holdings by the Tax Court, explores the strategic use of qualified offers, and argues that easement cases can be resolved when the IRS focuses on valuation instead of supposed technical flaws in documents.