20 December 2023

The latest installment of Sodium Podium – Andersen's regular column in Tax Notes – Wayne Trumbull (Managing Director – New York), Eric Anderson (Managing Director – San Francisco), and Edward Beeby (Senior Manager – San Francisco) explain why the state adoption of Internal Revenue Code Sec. 174, as amended by the Tax Cuts and Jobs Act, violates the foreign commerce clause. The authors also explore potential state defenses to justify any discrimination.

Link to article