Features

Navigating CAMT Post-OBBBA
A guide to the six brightest stars in a new galaxy

Almost four years after the enactment of the corporate alternative minimum tax (CAMT), many large corporations still operate in a regime that requires navigation by star chart. The celestial landscape has repeatedly shifted—from notice guidance issued in 2023 and 2024 to the 600-plus-page proposed regulations issued in late 2024 (generally… Read more »

Mind the Gap: When Tariffs and Transfer Pricing Collide
Enforcement risks at the intersection of tariffs and transfer pricing

Tariffs are forcing rapid changes to intercompany pricing, often under significant time pressure. Most global trade is intrafirm, and, in many cases, tax teams are asked to restore margins or reduce duty exposure using familiar transfer pricing tools. Those changes may be defensible for income tax purposes, but they can… Read more »

Rethinking the Narrow Construction of Tax Exemptions
Trends that could reshape disputes

Anyone facing a tax exemption dispute with a taxing authority knows it is an uphill battle. The maxim is that tax exemptions are construed narrowly to favor the state. State and local governments have wielded this principle as a cudgel: if any hole can be poked in a taxpayer’s entitlement… Read more »

Managing FEOC Restrictions and IRS Notice 2026-15
The new diligence standard for energy tax credits

The One Big Beautiful Bill Act (OBBBA) has added a new set of restrictions to the federal clean energy tax credit regime, known collectively as the foreign entity of concern (FEOC) framework. A FEOC, in broad terms, is an entity owned by, controlled by, or subject to the jurisdiction or… Read more »

Aligning Valuation Across Regimes
How tariffs can impact customs valuation and arm’s-length pricing for related parties

Related party transactions account for $2.3 trillion of the $5.3 trillion cross-border trade in the United States1 and sit at the intersection of two US regulatory regimes that assess the same intercompany pricing through different lenses. Customs valuation rules determine the value of imported goods for customs duty and tariff… Read more »

Corporate Apportionment of Partnership Income
Virginia ruling could have multistate implications

A decision issued by the Virginia Court of Appeals, FJ Management, Inc. v. Commonwealth of Virginia Department of Taxation, No. 0701-23-2 (Virginia Appeals Court 2024), addressed the computation of a corporation’s Virginia-apportioned taxable income, when the corporation owns a partnership interest. The Court of Appeals determined that, in this case,… Read more »

The Supreme Court Ruling and the Potential for Tariff Refunds: Their Impact on Transfer Pricing
A view from transfer pricing practitioners

When the United States introduced reciprocal tariffs in April 2025, public debate focused primarily on trade balances and industrial policy. Policymakers framed the tariffs as instruments for correcting perceived trade imbalances and reshaping supply chains. For multinational enterprises (MNEs), however, the tariffs represented something far more immediate and concrete. What… Read more »

Certainty by Design
A practical guide to prefiling agreements, closing agreements, private letter rulings, and tax opinions

Tax executives operate in a world where material transactions cannot wait for litigation to resolve interpretive uncertainty. The Internal Revenue Code is dense, dynamic, and increasingly shaped by subregulatory guidance and administrative interpretation. Although litigation remains the ultimate backstop, most public companies, private equity sponsors, and closely held businesses cannot… Read more »

Tax Deductions Drive Manufacturers to Revisit Facility Plans
Why QPP deductions are forcing a fresh look at facility ownership—lease, buy, or build?

Accelerated depreciation and industry-based tax incentives are nothing new from a tax policy perspective. First-year bonus depreciation, ranging from thirty percent to 100 percent, has existed in the Federal Tax Code for over twenty years. Congress has also routinely stepped in to provide tax deductions or credits to specific industries.… Read more »

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 »