Chadwick Rowland authored an article in the July-August 2026 issue of the International Tax Journal examining the treatment of previously taxed earnings and profits (PTEP) in partnership-owned controlled foreign corporation structures. In "PTEP and Partnerships: A Study," Rowland explores the unresolved complexities at the intersection of the PTEP and partnership tax regimes, with an emphasis on developments under the 2024 proposed PTEP regulations. Rowland suggests potential solutions to outstanding questions under those proposed regulations, concluding that without further guidance, taxpayers and advisors "will continue to operate in an uncertain space, navigating between statutory principle and incomplete regulatory machinery."

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