Ryan Finley

How about that Apple decision? I just wish more people would put up links to the judgment that everyone's seen by now. @StephanieSoong

@PHLEaglesNation Flip them, especially Clara. I don't think Jordan Love wants people saying that crap on his behalf

Jalen Carter posts some of the awful DM’s he received after making the tackle on the play that unfortunately injured Jordan Love.

For anyone with time to kill and a burning interest in the tax affairs of the sugar-water industry, allow me to suggest the following: taxnotes.com/featured-analy…

@goodtaxtakes @Brad_Setser @taxleonard (Assuming I took your meaning correctly.)

@goodtaxtakes @Brad_Setser @taxleonard I also don't think Treasury/IRS have the statutory authority to wipe out CSAs and proverbially sow salt into the soil. They most certainly don't have the inclination. And taxpayers could set up economically similar arrangements without calling them CSAs even if they could and did

@goodtaxtakes Many, myself included, agree with a lot of what Avi-Yonah says. Many others, myself sometimes included, benefit from reading stuff of his they don't entirely agree with. Not everyone feels that way, and that's cool. But there's nothing particularly cultish about any of it.

@InternationlTax Congrats, Mindy!

A Gold Award!

Lots going on in U.S transfer pricing litigation. Here's an overview of some of the highlights. pod.link/TaxNotesTalk

@SteveDalytax Go raibh maith agat. I look forward to reading yours.

@SteveDalytax Important usage tip - Hiberno-English may differ on this point, but in American English "kept" may more apt than "aged" to refer to something that went bad in a matter of weeks.

Next time.

@StephanieSoong @TaxStew Bold prediction, courtesy of DALL-E.

@StephanieSoong @TaxStew Indeed.

@ryanmfinley @TaxStew #GoBirds

ChatGPT's suggestion for an attorney fighting game. Our protagonist is obviously the tax lawyer -- the opponent seems to be an injured personal injury lawyer.

@taxleonard It's crazy how every installment of this genre uses a method (formulary apportionment) that has been repeatedly considered and repeatedly rejected.

I don’t easily call reports nonsense, but this is nonsense. “TaxWatch estimated the seven companies had made £60.5bn in UK revenues over the 2021 tax year (..) [and] estimated that the companies made £14.8bn in UK profits, by applying global profit margins.” 1/

@goodtaxtakes What's frustrating about this genre is that the baseline for what companies "should" have paid (formulary apportionment) has been repeatedly proposed and repeatedly rejected, both at national and multilateral levels. Right or wrong, that's just not how it works.

@StephanieSoong I've proposed "ALTERNATIVE ᚠ" (Fehu) and "alternative ᚢ "(uruz), but so far no takers

Also, we think everyone can agree that delegates should come up with less confusing names than "alternative A" and "alternative B."

A must-read for pillar 1 watchers: The big question in the amount B debate is whether it should take an objective approach (alternative A) or a qualitative approach (alternative B). @ryanmfinley explains why alternative B fans should rethink their stance. taxnotes.com/tax-notes-toda…

🚨 New podcast episode: @StephanieSoong chats with @ManalCorwin, the new @OECDtax director, about Corwin's vision for the organization. They also discuss the latest updates on the inclusive framework and two-pillar project. Listen now: taxnotes.co/3DvrAyb