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Clarity in a Changing Climate
In-house tax leaders sharpen fundamentals, leverage technology, and strengthen relationships to manage today’s volatility

When in-house tax professionals encounter uncertainty, it’s important to remember that their companies are facing the same turbulence. “Certainty is something we can never truly have, so for me it’s more about gaining clarity and focusing on what is within our control, amid all the uncontrollable,” says Josephine Scalia, vice… Read more »

Playing Ball in the Lone Star Stadium
Tax curveballs to watch for when conducting business in Texas

Over the last few years, some top US companies have relocated their headquarters to Texas or committed to doing so (among them Tesla, Chevron, SpaceX, and Coinbase). Similarly, the New York Stock Exchange announced that it would relocate its Chicago branch to Dallas. This move, of course, is a natural… Read more »

The Price of Regulatory Certainty
How does regulatory maturity shape the pricing of transferable tax credits?

Prior to the Inflation Reduction Act (IRA) of 2022, transferability of federal tax credits was limited in scope and fragmented across a small portion of programs. Monetization typically occurred through complex partnership structures or tax equity financing. These structures required specialized investors, longer structuring timelines, and higher transaction costs. For… Read more »

Considerations in Tax Refund Litigation
Is refund litigation the path to releasing “stuck” refunds?

The Internal Revenue Service has seen unprecedented changes this year. Approximately 25,000 IRS employees—or twenty-five percent of its workforce—have accepted the deferred resignation or retired or were laid off.1 When we wrote this article in November, the federal government had been shut down for more than four weeks with only… Read more »

How the IRS May Do More With Less
As the IRS modernizes with AI and other tech, it faces funding cuts and shifting enforcement priorities

Facing ongoing budget constraints and a significant reduction in workforce, the Internal Revenue Service is changing its approach to taxpayer service, enforcement, and collections. Taxpayers and tax practitioners are seeing early signs of how the IRS is leveraging technology and data analytics as well as returning to some old practices… Read more »

The Unconstitutionality of the Brazilian QDMTT
New tax on multinational groups raises legal and equity concerns

On December 30, 2024, the government of Brazil published Law 15,079, which went into effect on January 1, 2025. It instituted the Additional Social Contribution on Net Income (Adicional da Contribuição Social sobre o Lucro Líquido, or ACSLL), a tax that applies to multinational entities operating in Brazil. The ACSLL… Read more »

Sales Tax Traps for Disregarded Entities
A handful of states pose hidden compliance risks

Sales tax rules can be confusing, because states often take different approaches to the same tax concept. In most cases, sales tax obligations apply at the level of each separate legal entity—even if that entity is disregarded for federal or state income tax purposes. Although this rule generally applies in… Read more »

How Does Conformity Impact State Revenues After the OBBBA?
Changes in federal tax law reverberate across state budgets, with conformity choices shaping revenues in vastly different ways

State conformity with the Internal Revenue Code (IRC) refers to how states’ tax codes align with the federal tax code. Most states, for ease of administration and compliance, base their state income tax regimes on the federal IRC, either by using federal taxable income as a starting point or by… Read more »

OBBBA Modifications to US Taxation of International Income
Changes in the new law affect GILTI, foreign tax credits, and inventory sourcing rules, among other international tax provisions

The One Big Beautiful Bill Act (OBBBA), which was signed into law on July 4, has changed US taxation of multinational businesses. The most notable among these changes are various modifications that relate to the former global intangible low-taxed income (GILTI) regime enacted during the first Trump administration as part… Read more »

Are Tax Insurance Proceeds Taxable?
A practical guide for business tax directors on the evolving treatment of recoveries under tax insurance policies

Tax insurance has emerged as a cornerstone of corporate tax risk management. Whether companies use it to protect the outcome of a complex M&A transaction, to backstop the eligibility of a tax credit transfer, or to mitigate the risks of an uncertain deduction, tax insurance plays an increasingly vital role… Read more »