Features

The Proper Role of the Tax Department in an MNE’s Intercompany Transaction Framework
The tax department typically houses a company’s expertise in transfer pricing and is a major consumer of intercompany transaction details, but its responsibility for nonnative intercompany transaction functions can lead to significant risk and incremental income tax exposure

This article presents the challenges of collecting tax-related intercompany transaction information as well as common functional misalignments of intercompany-transaction-related responsibilities inside the multinational enterprise (MNE). It also identifies key intercompany transaction function subject matter expertise (SME) and aligns these SME units or individuals with specific intercompany transaction operations. This article… Read more »

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Dealing With Significant Multiemployer Pension Plan Issues in Corporate Transactions
Withdrawal liability could be jointly and severally owed by more than one entity in a corporate chain

If your company has targeted or is targeting another entity with a unionized workforce, you should pay particular attention to associated pension obligations. In recent years, a combination of industry and economic factors has led to the massive underfunding of many multiemployer pension plans. Such underfunding can result in substantial… Read more »

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TEI Roundtable No. 25: To Insource or to Outsource? That’s the Question
Corporate culture determines whether outsourcing adds value

Whereas the decision to outsource key components of the tax function may have been cyclical in the past, increasingly outsourcing looks like a trend that’s not going away. But what goes into making that decision, and is there room for a hybrid model that combines insourcing and outsourcing? To find… Read more »

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Data Transformation—Where to Begin?
What once took tax professionals months now takes moments—but challenges remain

With the advent of digitization tools comes the potential to transform and index massive data sources without the current dependency on IT and coding. We are approaching as significant a cultural shift in the tax profession as Facebook and the iPhone were in our day-to-day lives. What comes is a… Read more »

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True, Correct, and Complete: On-time Filing of State and Local Tax Returns Without Clear, Consistent, or Practical Guidance
In a GILTI world, taxpayers need to make their way without a compass

While state and local tax is rife with uncertainty, the signature block of a state or local corporate income tax return is often deceptively simple and definitive. Typically, the signature certifies that the return is “true, correct, and complete.”1 From a practical standpoint, however, state and local corporate tax returns… Read more »

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Responses to Federal Tax Reform in Key States
Keeping pace with developing federal rules has challenged even the most sophisticated corporate tax departments

A tsunami of change has roiled the normally calm waters of state conformity to the Internal Revenue Code (IRC) as a result of federal tax reform. Passed in December 2017, shortly before state legislatures went into session in 2018, the Tax Cuts and Jobs Act of 2017 (PL 115-97), hereafter… Read more »

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TEI Roundtable No. 24: Putting SALT on the Table
Corporate tax professionals face a plethora of vexing state and local issues

Digitization, human capital, greater efficiency, tax reform, Wayfair. To corporate tax professionals plying their trade in the state and local space, these aren’t just buzzwords. They’re challenges and opportunities that dominate their daily activities. So, what keeps these SALT professionals up at night? To address these issues, we convened a… Read more »

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Nexus: Reports of Its Death Are Clearly Premature
Nexus must still be addressed before taxes can be imposed

In the wake of South Dakota v. Wayfair Inc.1 and the U.S. Supreme Court’s endorsement of economic nexus, a subject of wide discussion has been whether nexus issues are dead in the context of sales tax and corporate income tax. Two recent developments indicate that, while the framework for analyzing… Read more »

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Technology and Automation: A Road Map for State and Local Tax Professionals
Challenges include spreadsheet-based calculations, manual tax software inputs and overrides, and cumbersome work papers

Tax functions today are under increased pressure to make processes more efficient and ensure proper compliance and reporting, while still taking time to analyze and synthesize growing volumes of raw data to provide more strategic insights. Predictably, the increased focus on analytics and strategic reporting drives the need for organizations… Read more »

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Part V: Section 965 Transition Tax
Yes, some issues are likely to persist for years after you’ve paid the tax

The Tax Cuts and Jobs Act (TCJA) added Section 965 to the Internal Revenue Code to tax earnings held offshore by controlled foreign corporations (CFCs) going back to 1987. In general, this transition tax is the price that U.S. persons who have accumulated earnings in CFCs must pay for the… Read more »

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