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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 »

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 »