Social Media Ideas for Base Erosion And Anti-Abuse Tax (Beat)

International Tax Competitiveness Index 2026

While there are many factors that affect a country's economic performance, taxes play an important role. A well-structured tax code is easy for taxpayers to comply with and can pro...

Power and Tax Policy: When Does Leveraging Market Access as a Coercive Geoeconomic Tool Succeed?

While economic levers like sanctions and tariffs have long been recognized as geoeconomic tools, tax policies have rarely been considered a part of this toolkit.

Even an Ideal Business Tax Base Can’t Justify an 80 Percent Business Tax Rate

There is a real danger that the well-founded admiration of expensing can slip into the belief that rates will not matter if the business tax base is correctly designed. Avi-Yonah’s...

Pro Rata Share Determinations Under the One, Big, Beautiful Bill Act: Analysis of the Proposed Regulations

Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss, REG-115646-25, 91 Fed. Reg. _____ (proposed Aug. 26, 2026) The Department of the Treasury and the Internal R...

Allocation and Apportionment of Foreign Source Deductions: Technical Analysis of Proposed Regulations Under Sections 250...

Department of the Treasury, Internal Revenue Service, Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income, N...

Bloomberg: Tax Group Calls Economic Substance Doctrine a Dangerous Tool

Bloomberg (James Matheson), Tax Group Calls Economic Substance Doctrine a ‘Dangerous Tool Courts must first determine the economic substance doctrine’s relevance to a transaction b...

Foreign Tax Advantages after the Tax Cuts and Jobs Act

Anmol Bhandari and Ellen McGrattan (Minnesota) have a new NBER working paper, “Foreign Tax Advantages after the U.S. Tax Reform of 2017” (September 2026). Here is the abstract: We...

Big Tech Is Raking in Enormous Tax Breaks for AI Development

OBBBA’s expensing provision is becoming especially lucrative for the companies building out AI infrastructure right now. There is no evidence whatsoever that tax breaks are necessa...

POLITICO: Corporate Tax Payments Plunge as AI Feasts on New Incentives

A generous tax break on capital investments Republicans created in 2025 wasn't designed specifically for the AI boom, but hyperscalers are making the most of it.

Foreign Tax Credits Against the Net Investment Income Tax: A Critical Analysis of the Federal Circuit’s Decisive Rulings...

Estate of Paul Bruyea v. United States, F.4th , No. 25-1563, ECF No. 58 (Fed. Cir. Aug. 31, 2026), reversing Bruyea v. United States, 174 Fed. Cl. 238 (2024). Matthew Christ...

IRS threatens crackdown on array of Wall Street tax dodges

The Treasury Department took a big step toward curbing a Wall Street boom in investment strategies that cut tax bills, with a notice signaling potential action.

Meta’s Outlandish Tax Breaks for AI Data Centers

Meta is claiming the research tax credit – a tax break meant to encourage innovation and experimentation – to pay for the equipment it uses in data centers to power its AI activiti...

Premium Tax Credit Regulations Under the One, Big, Beautiful Bill Act: Technical Analysis for Tax Professionals

Department of the Treasury, Internal Revenue Service, Premium Tax Credit, Notice of Proposed Rulemaking and Notice of Public Hearing, REG-101576-26, RIN 1545-BS15, 26 CFR Part...

The Destination-Based Cash Flow Tax Remains a Strong Option for US Business Tax Reform

A Destination-Based Cash Flow Tax (DBCFT) reduces the tax code’s penalty on investment, narrows its bias toward debt over equity, and removes much of the incentive to shift profits...

Treasury Announcement of Automatic Enrollment Completion for Trump Accounts: Technical Analysis of Account Claiming, See...

Trump Accounts, 91 Fed. Reg. 63200 (Sept. 30, 2026) (codified at 26 C.F.R. pt. 1) (TD 10056) Trump Accounts, 91 Fed. Reg. 63215 (proposed Sept. 30, 2026) (to be codified at...

Technical Analysis of Treasury Decision 10056 and Proposed Regulations CC-00226466-26: The New Regulatory Framework for...

Trump Accounts, 91 Fed. Reg. 63200 (Sept. 30, 2026) (TD 10056); Trump Accounts, 91 Fed. Reg. 63215 (proposed Sept. 30, 2026) (CC-00226466-26) The Department of the Treasury an...

Tax Treatment of ETF Security Transfers: An Analysis of Revenue Ruling 2026-20 and Notice 2026-62

Rev. Rul. 2026-20, 2026-20 I.R.B. 1, September 28, 2026 Notice 2026-62, 2026-20 I.R.B. 1, September 28, 2026 In a coordinated regulatory release, the Department of the Treasu...

Bloomberg Tax: Data-Center Spenders Save Billions From Depreciation Tax Break

“It’s as clear a case as you’re ever going to imagine of rewarding a company for doing something markets were already telling it to do,” said Matthew Gardner, senior fellow at the...

‘Black Holes’ for Capital-Gains Tax Come Under Treasury Fire

The IRS drew new boundaries around 351 conversions, targeting cases in which, as part of a prearranged plan, an ETF effectively serves as a conduit to convert one set of appreciate...

Full Abatement of Penalties and Surcharges for Outstanding Tax Liabilities Continues in 2027

Treasury Follows Through on “Too Good to Be True” ETF Tax Strategies

In July, Treasury officials warned that they were scrutinizing a burgeoning category of tax-aware investment strategies. At the time, Treasury stopped short of issuing guidance. We...

Alternative Apportionment: 2026 Flashpoints

Amy Hamilton (Tax Analysts): Alternative Apportionment: 2026 Flashpoints At the FTA conference, Fort said that courts and administrators have long struggled to apply section 18-sty...

Tax-slashing strategy popularized by largest hedge fund faces IRS crackdown

A strategy popularized by AQR to help wealthy people slash their taxes on ordinary income is facing a sign that authorities are preparing to clamp down.