The Supreme Court’s decision in Mayo that the Administrative Procedures Act applies to actions of the Internal Revenue Service has changed the rules of engagement for tax controversies.
Over the last decade, technology has secured a mainstream role in the optimization of the tax function while creating a huge new opportunity in the human resource side of tax department operations.
Recent decisions from the Tax Court combined with recent legislative and administrative initiatives and an environment where tax planning strategies have each contributed to a public that views tax planning at best with a skepticism and perhaps worse.
The American Taxpayer Relief Act of 2012 (“ATRA”) signed into law by President Obama on January 2, 2013, brings to
an end more than a decade of uncertainty for estate planners and their clients.
If you are encountering ACS and pains because the PIC in your BMF was caused by an FTD, maybe it's time to yell STAUP! Plain English translation: if the Automated Collection System is hounding you...
If an outstanding debt instrument is modified, or is exchanged for a new debt obligation of the issuer, a taxable exchange will occur if the terms of the outstanding instrument (hereinafter, the "old debt") are significantly modified...
t is rare that global transfer pricing strategies of multinational enterprises ("MNEs") find their way onto front page coverage in financial center newspapers and magazines. This has been the case in recent periods...
Following the major events in the UK last year, the tax avoidance debate has continued to develop at a surprisingly fast pace in 2013. Part 1 of this article provides an overview of the main developments to date, up to the G20 meeting in Moscow.
In a sharply-divided 5-4 opinion, the Supreme Court of the United States in United States v. Home Concrete & Supply LLP1 rejected the Internal Revenue Service’s position that an understatement of...
Complying with state abandoned and unclaimed property (AUP) reporting requirements has become a significant issue for many business organizations during the past 10 years.
TEI's 2011-2012 Corporate Tax Department Survey provides tremendous insight into the operations of a modern tax department, as well as new and emerging trends, including those related to leading practices for minimizing tax risk.
The Internal Revenue Service has contacted you to let you know that it will be opening an examination of the company’s tax return. Or, perhaps, your company is one of those lucky companies under constant examination, a Coordinated Industry Case.
A recent Thomson Reuters poll of 229 tax executives revealed that difficulty reconciling data and the volume of data being processed are top data management issues affecting tax compliance.
Since 2007, China has effected tax reforms in the areas of enterprise income, turnover, and property taxes - areas that have gained renewed emphasis pursuant to China’s 2011 12th Five-Year Plan
This is one in a series of "practice notes," providing readers with important background or updates on important issues affecting the avoidance or resolution of controversies with tax authorities.
As with any new and complicated regime, FATCA has generated much discussion and debate, mostly among U.S. tax advisers and financial institutions, and to a lesser extent among non-financial companies.
The IRS's recent tangible property regulations pose significant challenges for taxpayers. The mechanics of complying with the new rules are addressed in two IRS revenue procedures, Revenue Procedures 2012-19 and 2012-20.
Based on anecdotal evidence (including presentations at educational programs and discussions at networking sessions), the prevailing approach for disclosing “uncertain tax positions”...
Editor's Note: This is the first in a series of "Practice Notes," providing readers with important background or updates on important issues affecting the avoidance or resolution of controversies with tax authorities.
All taxpayers that acquire, produce, or improve tangible property will need to evaluate whether to change their methods of accounting to comply with income tax regulations that were recently issued by the Internal Revenue Service and the U.S. Department of the Treasury. Commonly referred to as “the repair regulations,” the new rules generally became effective on January 1, 2012.
Many U.S. companies have formed captive insurance companies to achieve significant benefits, but the decision whether to form a captive is often clouded by misconceptions and a failure to recognize both the business and tax implications involved.
Tax executives know that their professional raison d'etre is to manage global tax risks and create value by minimizing the tax burden of their companies. They also know this is increasingly difficult to do against a backdrop of relentless regulatory change, globalization of business, heightened scrutiny on all fronts, and resource constraints.
Editor's Note: As a recently retired territory manager with the Internal Revenue Service’s Large Business and International Division, Michael Gregoy had an opportunity to see how in-house tax professionals and their advisers worked...
Corporate taxpayers undergoing certain tax-free transactions now have several more options to determine their tax basis in the acquired Target stock.
In 2003, Mark Everson, then Commissioner of Internal Revenue, commented ruefully that it took the IRS five years to complete an audit of a corporate tax return.
In today’s technology-driven economy, many multinational enterprises are beginning to take advantage of cloud-computing technology in their global infrastructure and market facing-activities.
The Internal Revenue Service’s Generic Legal Advice Memorandum AM2011-003, dated August 18, 2011, is one of the most talked about internal IRS opinions in recent years This so-called GLAM addresses the check-the-box liquidation of an insolvent foreign ...
The tax department faces an increasingly difficult operational environment given today’s challenges. There is a broad effort underway at many companies to boost productivity, but it is not always easy to know where to start.
At the end of August, the Internal Revenue Service issued Revenue Procedure 2011-42, which provides guidance to taxpayers using statistical sampling to support a tax return position.