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October 1, 2014 - 8:59 AM EDT
A Very Good Idea to Curb Incentive Abuse
by David Brunori
Politicians in California have taken a bold step toward reigning in economic development consultants.
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September 29, 2014 - 1:27 PM EDT
Can Congress Pass Tax Reform That Would Stop Inversions?
by Martin A. Sullivan
To truly stop inversions, tax reformers will have to inflict pain on foreign companies doing business in the United States.
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All blog posts by Martin A. Sullivan
September 25, 2014 - 2:15 PM EDT
The Hobgoblin of Little Minds
by Christopher Bergin
The Obama Administration has been working feverishly all summer to create a scary new Halloween character for this year: the corporate tax inversion.
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September 24, 2014 - 1:19 PM EDT
Taxing the Cloud
by Cara Griffith
Of nine states that have recently issued administrative guidance on the taxability of cloud computing services, only two have found the services taxable. The remaining seven have determined cloud computing is not taxable.
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September 19, 2014 - 10:07 AM EDT
Renouncing the Dogma of Surrey’s Infallibility
by Ajay Gupta
Treasury’s export of Stanley Surrey’s arm’s-length standard was perhaps the most successful case of ideological conversion in the arena of international tax policy. Even as the United States inches away from that construct, the OECD clings to it with a zeal befitting a convert. Treasury may very well have to renounce the dogma of Surrey’s infallibility before true reform in the global transfer pricing regime can take place.
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September 18, 2014 - 9:11 AM EDT
Should We Tax Away Huge Fortunes?
by Joseph J. Thorndike
Sen. Bernard Sanders wants to rein in the runaway billionaires. In a recent piece for The Huffington Post, the Vermont independent (and apparent presidential candidate) made the case for a progressive estate tax.
[Read More]  (3 comments)

All blog posts by Joseph J. Thorndike
August 25, 2014 - 12:54 PM EDT
Fracking Taxes Help States Now, but What About the Future?
by Jeremy Scott
As bad as the federal budget picture looked during the Great Recession, the fiscal climate in the states was worse. The federal government used stimulus spending to prevent many states from having to make sharp cuts in services because of steep declines in sales, income, and corporate tax revenues. However, the state fiscal picture is looking much better. For the third year in a row, state tax revenues increased, according to the National Conference of State Legislatures. While things might be looking up for states, there are causes for concern because much of the increase in some states is driven by energy taxation, related to a boom in the fracking industry that won't last forever.
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All blog posts by Jeremy Scott
July 11, 2014 - 9:39 AM EDT
International Tax Trending
by Mindy Herzfeld
This week’s international tax highlights include Jean-Claude Juncker’s agenda for EU tax policy, changes in the IRS’ international administration, and continued assertiveness by the U.S. and other governments in pursuing tax evasion while BEPS goes into sleep mode.
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All blog posts by Mindy Herzfeld
April 29, 2014 - 9:00 AM EDT
Dreams of Tax Reform
by Clint Stretch
At the risk of revealing too much of my sentimental side, I have to admit that I’m a huge Patsy Cline fan. So I recently found myself at the small but carefully curated Museum of the Shenandoah Valley in Winchester, Va., which is holding a special exhibit on Patsy’s life and career.
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Federal Tax News from

For Wednesday, October 1, 2014

DOJ Official Downplays Effect of Clarke on Summons Enforcement

Court Holds Investigation Records Are Not Return Information

Civeo Cites Tax Benefits in Opting for Re-domicile Over REIT

News Analysis: Could the U.S. Embrace a Carbon Tax?

Floating Net Asset Value Method Doesn't Require Formal Election

District Court Strikes Down 'Arbitrary' Premium Tax Credit Rule

Subscribers to Expert3 or Tax Notes Today receive access to the full content for these articles plus many more on a daily basis. Our automated system can send you summary e-mails with links to the full content.
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State Tax News from

For Wednesday, October 1, 2014

Boeing Announces More Layoffs in Washington Following $9 Billion Incentive Package

Lead Texas Compact Case Now in Appeals Court

D.C. Sales Tax Changes Take Effect; Timetable for Corporate Changes Less Clear

Sales Tax Increase Is Too Little Too Late to Save Arkansas Hospital

Connecticut Panel Begins Comprehensive Study of State's Tax System

Tennessee Lawmakers Offer Little in Way of Solutions to State Budget Woes

Subscribers to Expert3 or State Tax Today receive access to the full content for these articles plus many more on a daily basis. Our automated system can send you summary e-mails with links to the full content.
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International Tax News from

For Wednesday, October 1, 2014

European Commission Outlines State Aid Cases Against Apple and Fiat

BEPS Solutions Must Go Beyond Transfer Pricing Rules, Stack Says

Arm's-Length Principle Insufficient to Price Financial Transactions, Practitioners Say

Distinguishing Ex-Ante From Ex-Post Intangible Returns

Foreign Investment Partnership in China Receives 25 Percent Tax Bill on Profit Distributions

Compliance Remains a Concern for Mexican Outsourcing Companies

Subscribers to Expert3 or Worldwide Tax Daily receive access to the full content for these articles plus many more on a daily basis. Our automated system can send you summary e-mails with links to the full content.
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Featured News

September 29, 2014
Pension Smoothing Risks Losing Money, but Few Alternatives Seen
by Luca Gattoni-Celli
Despite its use as an offset in the recently enacted bill replenishing the Highway Trust Fund, policy analysts say that pension smoothing does not ultimately increase tax revenue and risks costing money, but even those who question its legitimacy see few politically viable alternative offsets.

September 25, 2014
Inversion Guidance Hits Pending Deals, Not Previous Inverters
by Andrew Velarde and Kristen A. Parillo
New Treasury guidance aimed at making inversions more difficult to accomplish as well as substantially reducing the tax benefit from inverting includes several significant changes to existing rules, but only punishes yet-to-be completed inversions, a practitioner said September 23.

September 24, 2014
Practitioners Highlight State Guidance on Taxability of Cloud Computing
by Amy Hamilton
Several states within recent months have published administrative guidance on the taxability of cloud computing services, while two states have adopted statutory language or regulations addressing the matter, prominent attorneys said September 22.

September 22, 2014
Professor Shay Got It Right: Treasury Can Slow Inversions
by Steven M. Rosenthal
In a recent Tax Notes article, Shay argued that Treasury could write regulations to reduce the tax incentives for U.S. corporations to expatriate. Rosenthal agrees with Shay and analyzes the legal support for regulations under section 385.

September 12, 2014
40 Years in SALT: An Interview With Art Rosen
by Doug Sheppard
This edition features an interview with SALT luminary Art Rosen of McDermott Will & Emery, who is celebrating his 40th year in state and local tax. Though perhaps best known in recent years for his advocacy on federal business activity tax legislation, not to mention electronic commerce, Rosen has also racked up a long list of other accomplishments, some of which are touched on here.

September 10, 2014
News Analysis: Will New Anti-Inversion Measures Save Allergan?
by Ajay Gupta
In its struggle to fend off a $53 billion hostile takeover bid by Canada's Valeant Pharmaceuticals, California-based Botox maker Allergan Inc. is marshaling all available defenses, including reaching out to officials in the Obama administration, but it is uncertain whether additional anti-inversion measures will help its cause.

September 10, 2014
News Analysis: Grossing Up an Inversion Tax
by Ajay Gupta
Medtronic Inc. will pay $63 million to insulate its executive officers and directors from the consequences of an excise tax that will be triggered on completion of a transaction announced June 15 in which the company will merge with Covidien PLC and concurrently invert to Ireland.

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Video Channel

Watch Tax Analysts' video featuring a coversation with Lawrence B. Gibbs, former IRS Commissioner and a member of the law firm Miller & Chevalier, in which he discusses the current state of the IRS and its challenges.

Tax Analysts TV

Watch Tax Analysts' video examining how some businesses are effectively audit proof. Read the supplementary article here.

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Watch the video of our conference on the taxpayer bill of rights.

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Watch Marty Sullivan's interview on C-SPAN discussing tax avoidance.

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Watch a discussion on the net investment income tax with its drafters.

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