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Tax Notes Talk
Tax Notes Talk
Tax Notes

A discussion of cutting-edge developments in tax, including up-to-the-minute changes in federal, state, and international tax law and regulations.

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Episodes

What’s a U.S. Trade or Business? Analyzing YA Global

William McRae of Cleary Gottlieb discusses the U.S. Tax Court’s decision in YA Global Investments v. Commissioner and what it... more

29 Mar 2024 · 33 minutes
Senate Stasis: An Update on Congress’s Tax Deal

Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword discuss the roadblocks the Tax Relief for American Families and... more

22 Mar 2024 · 17 minutes
An Update on Pillar 1 Amount B

Tax Notes chief correspondent Stephanie Soong discusses the latest developments surrounding amount B under pillar 1 of the OECD’s two-pillar... more

15 Mar 2024 · 14 minutes
Navigating the Corporate Transparency Act

Christine Green of Steptoe & Johnson PLLC discusses the Corporate Transparency Act and the recent litigation regarding its constitutionality. For... more

08 Mar 2024 · 26 minutes
Medtronic, 3M, Abbott Labs, Oh My! Transfer Pricing Update

Tax Notes contributing editor Ryan Finley discusses the latest developments in three transfer pricing cases — Medtronic, 3M, and Abbott... more

01 Mar 2024 · 38 minutes
Taxing Billionaire Borrowing: A New Kind of Wealth Tax?

Professors Edward Fox and Zachary Liscow discuss their proposal for a new tax on billionaires that would apply to borrowing... more

23 Feb 2024 · 30 minutes
Tracking the Latest on the House Tax Reform Plan

Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword discuss the key provisions of the Tax Relief for American... more

16 Feb 2024 · 20 minutes
The Plastic Problem: Using Tax to Protect the Environment

Professor Roberta Mann of the University of Oregon School of Law explains how taxing single-use plastics could help combat their... more

09 Feb 2024 · 33 minutes
Liberty Global and the Economic Substance Doctrine

Tax Notes managing legal reporter Andrew Velarde discusses the economic substance doctrine dispute in Liberty Global Inc. v. United States... more

02 Feb 2024 · 15 minutes
What to Expect in the 2024 Filing Season

Kelly Phillips Erb, known online as Taxgirl, discusses the 2024 filing season’s challenges and considerations in light of the IRS’s... more

26 Jan 2024 · 33 minutes
Moore 2.0? Analyzing Altria Group Inc. v. United States

Tax Notes contributing editor Robert Goulder discusses the downward attribution dispute in Altria Group Inc. v. United States and the... more

19 Jan 2024 · 21 minutes
Spotlighting Tax Transparency Around the Globe

Tax Notes contributing editor Nana Ama Sarfo discusses global tax transparency efforts, specifically beneficial ownership registries and country-by-country public reporting.... more

12 Jan 2024 · 16 minutes
State Tax Policy Trends to Watch in 2024

Stephanie Do of the Council On State Taxation discusses key state tax policy topics that are likely to see action... more

05 Jan 2024 · 31 minutes
2024 U.S. Tax Legislation Forecast

Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2023 developments in U.S. tax legislation and speculates what may lie... more

29 Dec 2023 · 35 minutes
Year-End Collection: Tax Oddities of 2023

Tax Notes reporters recap some of the strangest stories they encountered in 2023, from a video game that can prepare... more

22 Dec 2023 · 22 minutes
A Recap of SCOTUS Oral Arguments in Moore v. United States

Tax Notes managing legal reporter Andrew Velarde breaks down the Supreme Court's oral arguments in Moore and predicts what's next... more

15 Dec 2023 · 30 minutes
The Reporter's Notebook: Stories From Covering the OECD

In honor of Tax Notes Talk's 300th episode, Tax Notes chief correspondent Stephanie Soong reviews her tax career and coverage... more

08 Dec 2023 · 18 minutes
Taxing Carbon at the Border

Tax Notes chief correspondent Amanda Athanasiou discusses the growing global popularity of carbon border adjustment mechanisms, the EU’s new regime,... more

01 Dec 2023 · 14 minutes
Cryptoassets and State Taxation

Wally Hellerstein of the University of Georgia Law School discusses the emerging state guidance for taxing cryptoassets. For more on... more

22 Nov 2023 · 26 minutes
Taxing the Fast-Fashionistas

Tax Notes contributing editor Nana Ama Sarfo discusses how lawmakers across the globe are looking to taxes to address problems... more

17 Nov 2023 · 18 minutes
Diversity and the Tax Bar

Sanessa Griffiths of Skadden, Arps, Slate, Meagher & Flom LLP discusses the lack of diversity in the tax bar and... more

10 Nov 2023 · 18 minutes
Navigating New Guidance on the Corporate Alternative Minimum Tax

Mike Resnick of Eversheds Sutherland discusses the effects on taxpayers of the corporate alternative minimum tax and its recently released... more

03 Nov 2023 · 36 minutes
IRA Energy Credits, Part 2: Proposed Regs and What’s Next

In the second of a two-episode series, Tim Jacobs of Hunton Andrews Kurth continues his discussion of the energy credits... more

27 Oct 2023 · 38 minutes
IRA Energy Credits, Part 1: History and Early Guidance

In the first of a two-episode series, Tim Jacobs of Hunton Andrews Kurth discusses the energy credits enacted in the... more

20 Oct 2023 · 31 minutes
The EU's Latest Plan to Simplify Corporate Taxation

Tax Notes reporter Elodie Lamer discusses the Business for Europe: Framework for Income Taxation (BEFIT) initiative, the European Commission’s latest... more

13 Oct 2023 · 17 minutes
Race-Based Poll Taxes and 20th-Century Discrimination

Professor Jeremy Bearer-Friend of the George Washington University Law School discusses poll taxes in the 20th century and how they... more

06 Oct 2023 · 37 minutes
IRS Key Updates: ERC, EITC, and Government Shutdown Plans

Robert Kerr, formerly with the IRS and now with Kerr Consulting, discusses latest developments from the IRS, including the tax... more

29 Sep 2023 · 32 minutes
Cryptocurrency and the Newly Proposed Tax Rules on Digital Assets

Garrett Brodeur, a tax attorney based in Washington, D.C., discusses the recently released proposed regulations for the cryptocurrency industry and... more

22 Sep 2023 · 23 minutes
An Update on the Foreign Tax Credit Rules and IRS Relief

Tax Notes reporter Andrew Velarde discusses the latest developments on the final regulations for claiming foreign tax credits, including the... more

15 Sep 2023 · 17 minutes
The Intersection of U.S. Tax Law and Democracy

Professor Clint Wallace of the University of South Carolina School of Law discusses his argument for using tax policy to... more

08 Sep 2023 · 36 minutes
Checking In With Congress: Fall 2023 Preview

Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword preview what to expect from Congress in tax policy this... more

01 Sep 2023 · 20 minutes
Tax and the Future of Artificial Intelligence

John McGowan of HubSync discusses artificial intelligence and its role in the tax field. For additional coverage, read these articles... more

25 Aug 2023 · 23 minutes
Pillar 1 Amount B: Disagreements and Divides

Tax Notes contributing editor Ryan Finley provides an overview of amount B from pillar 1 of the OECD’s two-pillar corporate... more

18 Aug 2023 · 16 minutes
The Employee Retention Credit: Scams and Successes

Tom Cullinan, a former IRS official now with Chamberlain Hrdlicka, discusses the basics of the employee retention credit, the recent... more

11 Aug 2023 · 35 minutes
Inside Bidenomics: Unpacking the President's Tax Priorities

Tax Notes White House reporter Alexander Rifaat discusses the Biden administration’s economic plan called “Bidenomics” and its effect on tax.For... more

04 Aug 2023 · 14 minutes
Manal Corwin Takes the Helm: Updates on the OECD Tax Reform Plan

Manal Corwin, the new director of the OECD's Centre for Tax Policy and Administration, discusses her vision for the organization... more

28 Jul 2023 · 35 minutes
Moore Money, More Tax Problems? Analyzing Moore v. United States

Professor Hank Adler of Chapman University discusses the income realization requirement dispute in the transition tax case Moore v. United... more

21 Jul 2023 · 26 minutes
The Evolution of International Corporate Taxation

Marna Ricker, EY’s global vice chair of tax, discusses how international tax advisers and corporate tax clients have handled recent... more

14 Jul 2023 · 26 minutes
How Fake News Affects the Tax World

Professors Kathleen DeLaney Thomas and Erin Scharff discuss fake tax news and the effect it has on public policy. For more,... more

07 Jul 2023 · 38 minutes
Let's Make a Deal: Examining the U.S.-Chile Tax Treaty

Tax Notes reporters Cady Stanton and Michael Smith discuss the recently passed U.S.-Chile tax treaty and the importance of tax... more

30 Jun 2023 · 28 minutes
House GOP Tax Package: The Kickoff for Congressional Bargaining?

Steve Rosenthal of the Urban-Brookings Tax Policy Center reviews the GOP tax package approved by the House Ways and Means... more

23 Jun 2023 · 37 minutes
Five Years of Wayfair: Continuing Complexity

Scott Peterson of Avalara discusses the South Dakota v. Wayfair decision, including how companies and states are faring five years... more

16 Jun 2023 · 30 minutes
Crisis Averted: Breaking Down the Debt Ceiling Bill

Tax Notes reporter Alexander Rifaat discusses the tax implications of the recently passed debt ceiling bill and gentleman’s agreement over... more

09 Jun 2023 · 13 minutes
U.S. Economic Update: Inflation, the Deficit, and the Debt Limit

Tax Analysts’ chief economist Martin Sullivan provides an overview of the state of the economy and how the recent debt... more

02 Jun 2023 · 21 minutes
We’re Free Filin’? Assessing the IRS’s Direct File Report

Former IRS Commissioner David Kautter, now with RSM, discusses the recently released report on the feasibility of an IRS-run direct... more

26 May 2023 · 31 minutes
State’s Victory: An Update on Maryland’s Digital Advertising Tax

Tax Notes reporter Andrea Muse provides an update on the state and federal lawsuits challenging Maryland’s digital advertising tax. Listen to... more

19 May 2023 · 13 minutes
Clarence Thomas’s Luxury Travel and the Gift Tax

Professors Bridget Crawford and Victoria Haneman discuss the estate and gift tax and how it could apply to the gifts... more

12 May 2023 · 29 minutes
Taxpayer Scores: Farhy Blocks International Reporting Penalties

Tax Notes reporter Andrew Velarde discusses the penalty dispute in Farhy v. Commissioner and the case’s implications for other penalties... more

05 May 2023 · 13 minutes
Emissions Free Trade: EV Tax Credit Sourcing Rules and the EU

Professor Kathleen Claussen of Georgetown Law discusses how the proposed regs for the new clean vehicle tax credit affect the... more

28 Apr 2023 · 32 minutes
Lies for Likes: Evaluating Social Media Tax Scams

Professor Samuel Brunson of Loyola University Chicago discusses social media tax scams highlighted in the IRS’s 2023 “Dirty Dozen” list... more

21 Apr 2023 · 35 minutes
Analyzing the IRS’s Inflation Reduction Act Spending Plan

Former IRS Commissioner Fred Goldberg, now with Skadden, shares his thoughts on the IRS’s strategies and proposals outlined in the... more

14 Apr 2023 · 42 minutes
Bad Credit: A Look at Switzerland’s Bank Secrecy

Tax Notes contributing editor Robert Goulder discusses the history of bank secrecy, Credit Suisse’s role in it, and the bank’s... more

07 Apr 2023 · 30 minutes
ChatGPT Takes on Tax

Tax Notes legal reporter Caitlin Mullaney discusses ChatGPT’s understanding of tax. For more, read "Off the Beaten Tax: Could the... more

31 Mar 2023 · 23 minutes
Grace Perez-Navarro: Tax Mainstay for 30 Years

Grace Perez-Navarro discusses her long career at the OECD Centre for Tax Policy and Administration and what’s next after her... more

24 Mar 2023 · 31 minutes
More of the Same: Breaking Down Biden’s Budget

Kyle Pomerleau of the American Enterprise Institute discusses the Biden administration’s fiscal 2024 budget and examines how the tax proposals... more

17 Mar 2023 · 29 minutes
Bringing Order to Chaos? Digital Services Taxes and Pillar 1

Tax Notes contributing editor Nana Ama Sarfo discusses digital services taxes and the OECD’s goal to solve related challenges through... more

10 Mar 2023 · 23 minutes
Paving the Way for the Next Generation of Tax Professionals

Tony Santiago of TaxSearch Inc. discusses how the tax profession is changing and offers advice on developing future tax leaders.... more

03 Mar 2023 · 30 minutes
IRS Victory: 3M Transfer Pricing Challenge Update

Tax Notes contributing editor Ryan Finley discusses the IRS’s major win in 3M and how it may affect other transfer... more

24 Feb 2023 · 17 minutes
Updates From IRS Criminal Investigation Deputy Chief

Tax Notes legal reporter Nathan Richman talks with IRS Criminal Investigation Deputy Chief Guy Ficco about the upcoming Advance Collaboration... more

17 Feb 2023 · 46 minutes
Examining Treasury’s Review of Racial Bias in the U.S. Tax Code

Professor Steven Dean of Brooklyn Law School discusses the U.S. Treasury’s Equity Action Plan and its progress on examining potential... more

10 Feb 2023 · 29 minutes
Analyzing the Constraints of the OECD Corporate Mediation Process

Tax Notes reporters Sarah Paez and Kiarra Strocko discuss what they found in an exploration of the OECD-supported mediation process... more

03 Feb 2023 · 28 minutes
A Closer Look at the National Sales Tax Proposal

Tax Notes Capitol Hill reporter Doug Sword discusses the latest national sales tax proposal in Congress, and contributing editor Robert... more

27 Jan 2023 · 31 minutes
Teaching Tax Law Critically and the Earned Income Tax Credit

Professor Diane Kemker of DePaul College of Law shares her argument for more coverage of the earned income tax credit... more

20 Jan 2023 · 39 minutes
Trump’s Tax Returns and the Future of Transparency

Tax Notes contributing editor Joseph J. Thorndike discusses the release of former President Trump’s tax returns and how they may... more

13 Jan 2023 · 33 minutes
2023 U.S. Tax Legislation Forecast

Tax Analysts Chief Content Officer Jeremy Scott reviews the 2022 developments in U.S. tax legislation and speculates about what may... more

06 Jan 2023 · 25 minutes
State Tax Policy Trends to Watch in 2023

Valerie Dickerson of Deloitte Tax LLP discusses key developments in state tax policy from 2022 that will likely remain relevant... more

30 Dec 2022 · 30 minutes
Year-End Collection: Tax Oddities of 2022

Tax Notes reporters recap some of the weirder stories they encountered in 2022, from the tax troubles of reality stars... more

23 Dec 2022 · 16 minutes
The TCJA Five Years Later: International Tax Issues

In the third of a three-episode series, former senior Treasury official Chip Harter discusses his experience creating the international tax... more

16 Dec 2022 · 38 minutes
The TCJA Five Years Later: Federal Tax Issues

In the second of a three-episode series, Jennifer Acuña, now with KPMG and former tax counsel for the Ways and... more

09 Dec 2022 · 28 minutes
The TCJA Five Years Later: State Tax Issues

In the first of a three-episode series, Steven Wlodychak, formerly with EY, discusses the creation of the SALT cap deduction... more

02 Dec 2022 · 30 minutes
Advancing the Pillars: An OECD Tax Reform Project Update

Tax Notes chief correspondent Stephanie Soong discusses how countries are approaching implementation of the OECD’s two-pillar corporate tax reform plan... more

23 Nov 2022 · 26 minutes
The Case for Taxing Prison Labor

Stephanie Hunter McMahon of the University of Cincinnati College of Law discusses why labor performed by incarcerated workers should be... more

18 Nov 2022 · 30 minutes
Should We Have a Robot Tax? Part 2

In the second of a two-episode series, Orly Mazur of SMU Dedman School of Law discusses her views on the... more

11 Nov 2022 · 32 minutes
Should We Have a Robot Tax? Part 1

In the first of a two-episode series, Ryan Abbott of the University of Surrey discusses his views on the tax... more

04 Nov 2022 · 32 minutes
IRS in Flux: New Funding and New Commissioner

Former IRS Commissioner Mark Everson, now with Alliantgroup, discusses the need to identify the agency’s next leader and how the... more

28 Oct 2022 · 33 minutes
Updates From the Tax Court: Post-COVID Plans and New Funding

U.S. Tax Court Chief Judge Kathleen Kerrigan discusses the court’s post-COVID transition and case management system, and how the additional... more

21 Oct 2022 · 35 minutes
Taking a Look Behind the Mic for Our Fifth Anniversary

It’s Tax Notes Talk’s fifth anniversary! Host David Stewart discusses the history of the podcast with current and former members... more

14 Oct 2022 · 29 minutes
Assessing the New U.K. Leadership’s Unexpected Tax Changes

Dan Neidle of Tax Policy Associates in London discusses the United Kingdom’s recent mini-budget and what effects the new tax... more

07 Oct 2022 · 32 minutes
The New Excise Tax on Corporate Stock Buybacks

Eric Solomon of Steptoe & Johnson LLP discusses the new excise tax on corporate stock buybacks and examines the issues... more

30 Sep 2022 · 35 minutes
Transfer Pricing Litigation Update II

Tax Notes contributing editor Ryan Finley discusses the latest updates in recent transfer pricing cases Eaton and Medtronic II. Listen to... more

23 Sep 2022 · 33 minutes
U.S. Tax Provisions Driving the Fight Against Climate Change

Lauren Collins of Vinson & Elkins LLP provides an overview of the new tax credits designed to reduce greenhouse gas... more

16 Sep 2022 · 32 minutes
$80 Billion in New Funding: What’s Next for the IRS?

Robert Kerr of Kerr Consulting LLC discusses how the $80 billion of additional funding for the IRS in the Inflation... more

09 Sep 2022 · 38 minutes
The Unexpected Tax Consequences of Overturning Roe v. Wade

Caroline Rule of Kostelanetz & Fink LLP discusses the post-Roe tax complications for employers covering abortion-related interstate travel expenses. For... more

02 Sep 2022 · 25 minutes
Is IRS Tax Enforcement Colorblind?

Professor Jeremy Bearer-Friend of the George Washington University Law School highlights key areas of the IRS’s tax enforcement where racial... more

26 Aug 2022 · 23 minutes
Analyzing the Corporate Alternative Minimum Tax

Reuven Avi-Yonah of the University of Michigan Law School discusses the new corporate alternative minimum tax and how it intersects... more

19 Aug 2022 · 32 minutes
Breaking Down the Tax Changes in the Inflation Reduction Act

Kyle Pomerleau of the American Enterprise Institute discusses the key tax provisions of the Inflation Reduction Act and what they... more

12 Aug 2022 · 30 minutes
Congress vs. Inflation: The Legislative Showdown

Tax Notes reporter Benjamin Guggenheim discusses the latest tax legislation on Capitol Hill: the recently passed CHIPS and Science Act... more

05 Aug 2022 · 27 minutes
Trouble Ahead? Inflation and the Coming Recession

Martin A. Sullivan, Tax Analysts’ chief economist, revisits the United States’ economic path to inflation and discusses mitigation efforts for... more

29 Jul 2022 · 30 minutes
Implementation Issues: An OECD Tax Reform Project Update

Tax Notes chief correspondent Stephanie Soong Johnston recaps the agreement on the OECD’s two-pillar corporate tax reform plan and discusses... more

22 Jul 2022 · 25 minutes
The Comey and McCabe Audits: Questions and Concerns

Tax Notes reporter Jonathan Curry discusses the IRS audits of former FBI Director James Comey and his deputy, Andrew McCabe,... more

15 Jul 2022 · 22 minutes
Superfund Taxes: The Cost of Cleaning Up the Environment

Nicholas Mowbray of BakerHostetler discusses the recently enacted Superfund excise taxes on chemicals and hazardous substances and some compliance concerns... more

08 Jul 2022 · 30 minutes
A Closer Look at Low-Income Taxpayer Clinics

La Posada Tax Clinic Director Robert Wunderle discusses the importance of low-income taxpayer clinics to the tax system and how... more

01 Jul 2022 · 29 minutes
The Advance Child Tax Credit: 2022 and Beyond

Elaine Maag of the Urban-Brookings Tax Policy Center looks at lessons learned from the 2021 advance child tax credit and... more

24 Jun 2022 · 22 minutes
How Canada Taxes Pro Athletes

Marie-France Dompierre of Davies Ward Phillips & Vineberg discusses how Canada taxes professional athletes who aren’t Canadian residents. For more,... more

17 Jun 2022 · 27 minutes
The Final Foreign Tax Credit Rules: Complaints and Confusion

Raymond Stahl of Ernst & Young discusses concerns about the final regulations for claiming foreign tax credits, particularly how they... more

10 Jun 2022 · 43 minutes
The European Parliament Comes to Washington

Johan Langerock, policy adviser in the European Parliament, discusses his visit to Washington, the future of the OECD two-pillar tax... more

03 Jun 2022 · 32 minutes
Examining Florida’s Removal of Disney’s Special Tax District

Tax Notes reporter Benjamin Valdez discusses the Florida legislation eliminating Disney's special tax district, what led to its passage, and... more

27 May 2022 · 14 minutes
Free for a Fee: Intuit's TurboTax Scandal

Tax Notes reporters Paul Jones and Nathan Richman discuss the $141 million settlement over Intuit’s TurboTax Free Edition program and... more

20 May 2022 · 21 minutes
First-Class Tax Opportunities: Golden Visas and Passports

Elodie Lamer and Nana Ama Sarfo of Tax Notes discuss the tax implications of golden visas and passports, which allow... more

13 May 2022 · 19 minutes
The Future of Tax Policy for Remote Workers

Timothy Noonan of Hodgson Russ LLP discusses how some states tax remote employees and the effect of temporary pandemic tax... more

06 May 2022 · 40 minutes
Adjusting for Climate Change: Clean Energy Tax Proposals

Beth Viola and Nicole Elliott of Holland & Knight discuss the latest clean energy tax proposals and the likelihood of... more

29 Apr 2022 · 23 minutes
Examining the Ukrainian Tax Implications of Russia’s Invasion

Valeria Tarasenko of Dentons Kyiv discusses the Ukrainian government’s tax policy changes in response to the Russian invasion. For additional coverage,... more

22 Apr 2022 · 35 minutes
IRS Commissioner Talks About the State of the Service

IRS Commissioner Charles Rettig discusses the current state of the tax agency, including the paper return backlog, technology improvements, and... more

15 Apr 2022 · 44 minutes
The Biden Budget: Build Back Better Again?

Rohit Kumar of PwC discusses the Biden administration’s fiscal 2023 budget, explaining the new proposals and how the budget is... more

08 Apr 2022 · 36 minutes
Who You Gonna Call: Tax Myth Busters

Tax Notes reporters Jonathan Curry and Caitlin Mullaney set the record straight on 10 common tax myths. For more coverage,... more

01 Apr 2022 · 17 minutes
Dynamic Duo: Meet the BEPS Inclusive Framework Co-Chairs

Marlene Nembhard Parker and Fabrizia Lapecorella discuss their partnership as the first co-chairs of the OECD inclusive framework on base... more

25 Mar 2022 · 35 minutes
Whirlpool Sends the Tax World Spinning

Tax Notes reporter Andrew Velarde discusses the tax structure dispute in Whirlpool v. Commissioner and the case’s future implications for... more

18 Mar 2022 · 22 minutes
The NCAA vs. Taxation: How Colleges Are Caught in the Middle

Professor Richard Schmalbeck of Duke University Law School discusses college sports and taxation, including the potential effect of compensation for... more

11 Mar 2022 · 35 minutes
Inflation, Tax, and the COVID-19 Economy

Martin A. Sullivan, Tax Analysts’ chief economist, provides an overview of the U.S. economy before and during the COVID-19 pandemic,... more

04 Mar 2022 · 23 minutes
State Tax Authority and Native Americans: Complex and Convoluted

Professor Adam Crepelle of the George Mason University Antonin Scalia Law School discusses the complicated tax relationship between U.S. states... more

25 Feb 2022 · 39 minutes
Tax Notes Talk
Whirlpool Sends the Tax World Spinning
Tax Notes Talk
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Description

Tax Notes reporter Andrew Velarde discusses the tax structure dispute in Whirlpool v. Commissioner and the case’s future implications for multinational companies.... more