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When economic substance becomes a litigation surprise
Economic substance has learned to wait.
The real barrier to AI in accounting is human, not technical
Modernization will come from small and consistent steps.
Trump Account or 529? How the Incentives stack up
Defaults start the story, but incentives decide where families finish.
The IRS looks weak. That is when fraud becomes most expensive.
Periods of visible weakness inside the IRS tend to produce the same reaction.
Transfer pricing enters a new era of volatility and scrutiny in 2025
The transfer pricing environment in 2025 has shifted faster than the IRS can hire, fire, or reinstate employees.
The slow unmaking of a tax institution
A system can survive change, but it struggles to survive forgetfulness.
The fragile certainty of Bonus Depreciation
Acceleration works until it becomes expectation, and expectation is the one thing the Code never guarantees.
When investigations become the punishment
The process always tells the story faster than the outcome ever will.
The Subsidy Reflex in the Age of AI
A subsidy becomes policy the moment no one remembers what it was meant to correct.
Tenth Circuit Limits Reach of Treasury Regulations in Liberty Global Case
Reliance on regulatory text alone no longer ensures safety—courts are reasserting the statute as the ultimate boundary for tax outcomes.
Florida Challenges California’s Corporate Tax Formula at the Supreme Court
Whether or not the Court takes the case, Florida’s challenge puts the constitutionality of single-sales-factor formulas squarely in the national…
Meta’s $16 Billion Tax Hit Shows Biden-Era Minimum Tax Still Has Teeth
Meta’s $16 billion tax charge shows that despite new corporate breaks, the Biden-era minimum tax remains one of the few guardrails keeping effective…
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