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From 30,000 Feet Into the Weeds

In this article, Professor Pomp makes various predictions regarding the future of the tax law. Artificial intelligence will continue to change the legal landscape. The IRS uses AI to predict the likelihood of nonpayment, abusive tax returns, underreporting, and nonfiling. It also uses AI to mine social media accounts for evidence of theft and tax fraud. Moreover, AI allows firms to analyze large data sets and predict how courts will resolve legal issues in tax cases. Pomp predicts litigation surrounding the use of market-based sourcing arising from ambiguous terms like “benefit,” “delivery,” and “use.” He also expects litigation resulting from the intersection of market-based sourcing and single-sales-factor apportionment. Pomp hopes that “but for” reasoning, urged by states hoping for beneficial apportionment outcomes, will be rejected. These states argue that “but for” the final step in a complicated multistate transaction—typically the payment by the end user—there would be no income to apportion. But this perspective ignores all of the “but for” causes that were necessary for that sale to occur. The European Union and the OECD will further recognize what the American states have known for decades: formulary apportionment is superior to arm’s-length accounting. Pomp also expects that more taxpayers will enter into joint ventures with American Indian Tribes to exploit the case law on tribal sovereignty and immunities.