COMMENTARY / SPECIAL REPORT IN THE WORKS A look ahead to planned commentary and analysis. A foreign language? Residency rules with an international spin (State Tax Notes) Timothy Noonan and Andrew Wright provide a review of New York’s 548-day rule and summarize rulings interpreting the test published by the New York State Department of Taxation and Finance. An analysis of Georgia’s high-technology exemption (State Tax Notes) Doug Nagode, Aaron Hooper, and Adam Nicoll examine Georgia’s high-technology sales and use tax exemption and offer insight into the requirements for a high-technology company to invoke this exemption. An economic framework for identifying the tested party (Tax Notes) Michael I. Cragg and David J. Hutchings argue that economic principles of competition can provide an appropriate measure of complexity in determining the tested party under the comparable profits method of transfer pricing. BEPS action 2 report on hybrids: A Canadian perspective (Tax Notes International) Jack Bernstein examines the impact that the final BEPS report on action 2 may have on the use of hybrid instruments in CanadaU.S. tax planning and financing structures. BEPS and tax compliance in Ghana (Tax Notes International) William Kofi Owusu Demitia identifies some of the compliance issues facing taxpayers in Ghana as the tax administration addresses base erosion and profit shifting. 1058 TAX NOTES, November 23, 2015 For more Tax Notes content, please visit www.taxnotes.com. (C) Tax Analysts 2015.

All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content. would apply, it can be anticipated that the government will argue that those taxpayers do not satisfy the injury-in-fact requirement for standing. However, as discussed in this report, the relevant case law provides ample support for the conclusion that the injury-in-fact requirement would be satisfied in those cases. .