Social Media Ideas for Making Sense Of Profit Shifting

Diving into the Differences Between Tax Transparency Regimes

The new public country-by-country reporting regimes adopted by the EU and Australia, and changes from the Financial Accounting Standards Board for financial accounts, are meant to...

The Wrapper Illusion

Can an LLC or partnership make tax anti-abuse rules disappear?

The Safe Harbor That Wasn’t: Deconstructing the Anti-Abuse Rule in SIH Partners LLLP v. Commissioner

SIH Partners LLLP, Explorer Partner Corp., Tax Matters Partner v. Commissioner of Internal Revenue, 167 T.C. No. 8 (August 6, 2026) In the highly structured world of corporate...

UK Withholding Tax on Interest- Simplification or Risk Shift?

Stopping the P.L. 86-272 Evasion

It is no secret that States abhor the protections afforded companies by P.L. 86‑272—the federal provision that prevents States from imposing an income tax in certain circumstances....

The Guardian view on global corporate tax: a $500bn prize that states must seize | Editorial

Donald Trump may reject the negotiations, but he cannot veto a global effort to make multinational companies answer to governmentsGovernments are told that public services must shr...

Treasury’s Excluded Property Sales Income Regulations under Section 250: Deconstructing the Proposed Guidance for Tax Pr...

Application of Section 250(b)(3)(A)(i)(VII) to Sales or Other Dispositions of Property, REG-117130-25, 91 Fed. Reg. _____ (proposed Aug. 20, 2026) (to be codified at 26 C.F.R....

The London office, the empty boxes and the £1bn tax loophole

Exclusive: How a court case over an unoccupied office block could end a widely used tax avoidance schemeFrom the outside, the seven-storey building at 2 America Square looks like a...

The tax-structure playbook for ultra-wealthy clients

The difference between bleeding a third of gains to taxes and being able to keep compounding isn't luck or a secret loophole. It's structure.

Seabrooke & Stausholm: How TaxTech Rewires Global Wealth Chains

Leonard Seabrooke (Copenhagen Bus. Sch.) & Saila Stausholm (Copenhagen Bus. Sch.), How TaxTech Rewires Global Wealth Chains, Fin. & Soc’y (forthcoming 2026): Technological...

The Partnership That Never Was

A disconnect between administrative convenience and substantive tax law may lead to compliance errors.

Alstadsæter, Johannesen, Le Guern Herry & Zucman on Transparency and Offshore Wealth

Annette Alstadsæter, Niels Johannesen, Ségal Le Guern Herry & Gabriel Zucman, “Global Financial Transparency and Offshore Wealth Accumulation” (NBER Working Paper, July 2026):...

Treasury Proposes Substantive Section 987 Relief for Controlled Foreign Corporations: Analysis of the CFC Exemption Elec...

Foreign Currency Gain or Loss of Controlled Foreign Corporations, REG-103844-26, 91 Fed. Reg. (proposed Aug. 14, 2026) On August 13, 2026, the Department of the Treasury and t...

How Malta Became a Tax Haven for Crocs and Other U.S. Companies

The Mediterranean archipelago is a hot destination for U.S. companies seeking to shield profits from income taxes.

Ring, Seim, and Zucman: Personal Holding Companies, Tax Progressivity, and Inequality

Marius Ring (UT Austin), David Seim (Stockholm University), and Gabriel Zucman (Paris School of Economics and Berkeley) have a new NBER working paper, “Personal Holding Companies,...

Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4)

Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance, REG-115145-25, July 31, 2026 The Department of the Treasury...

With the equalisation levy gone, how taxing digital profits has become complicated

The tech giants' India revenues are booming. But with the equalisation levy gone, taxing digital profits has become even more complicated.

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...

More on Tax-Aware Long-Short Investing Strategies

Loukia Gyftopoulou, Paige Smith & Charlie Wells (Bloomberg): The Ultrawealthy Tax Maneuver That’s Spooking Schwab and Fidelity For months, the brokerage had piled into one of t...

Tax has changed, but companies still operate as if it hasn't

The traditional tax department model, flawed to begin with, no longer fits how businesses operate and is insufficient to meet today's regulatory requirements.

When the Structure Isn’t Right: LLCs, Check-the-Box, and the §1045 Rollover (Part IV of IV)

Bloomberg Tax: Weaker Minimum Book Tax Rules Save Meta, Qualcomm Billions

“It’s pretty clear these two things are potentially at odds,” said Matthew Gardner, senior fellow at the Institute on Taxation and Economic Policy. “The more Treasury tries to gut...

How ONESOURCE and Orbitax turn Pillar Two compliance into an automated process

Most corporate tax departments entered the first major Pillar Two filing season already stretched. That isn’t new. Most tax departments … The post How ONESOURCE and Orbitax turn Pi...

N.Y. Times: Crocs Has a Trick for Dodging Taxes: a Tiny Office in Malta

In the New York Times, Jesse Drucker and Dylan Freedman have a new article, “N.Y. Times: Crocs Has a Trick for Dodging Taxes: a Tiny Office in Malta.” From the article: Take the st...