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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.

John L. Harrington examines the OECD's two-pillar approach to taxing the digital economy and how some of its components, especially pillar 1, could become building blocks for international tax change, whether specific to a jurisdiction or more broadly adopted.
Andrew Weiner argues that the petitioner in CIC Services, which was recently argued before the Supreme Court, presents an unconvincing case for reading the Anti-Injunction Act to allow pre-enforcement challenges to tax rulemaking, and he explains why that interpretation wouldn’t necessarily benefit taxpayers.
Ethan D. Millar of Alston & Bird LLP reviews legal and policy issues surrounding states' use of estimation in the unclaimed property context and argues that the justifications raised by Delaware and contract audit firms for supporting the domicile-takes-all approach are invalid and should be rejected by courts, holders, and states.