The near adoption of Worldwide Combined Reporting (WWCR) in Minnesota has led to a blizzard of critical claims about WWCR from corporate tax lobbyists, the Tax Foundation, and the editorial board of the Wall Street Journal. These various groups have made a number of policy arguments that do not...

This essay analyzes the retroactivity issues that have been raised in regard to mark-to-market and other accrual income tax reforms, with a focus on New York State’s proposed Billionaire Mark-to-Market Tax Act