Features

Claiming a Foreign Tax Credit—How Exhausted Do You Really Have to Be?
Missteps by taxpayers in this area can be costly and result in avoidable double taxation

The Internal Revenue Service recognizes that “foreign government audits of U.S. taxpayers have become more frequent and, at times, more aggressive.”1 Consequently, the number of foreign tax contests and payments made by taxpayers to resolve those contests are on the rise. The IRS has signaled through its training materials and… Read more »

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Deconstructing MAP and APA
Increased demand, new requirements to engage with IRS Examination, and efforts to come to terms with untested provisions of the TCJA have stretched APMA resources

In recent years, many taxpayers have effectively used mutual agreement procedure (MAP) cases and advance pricing agreements (APAs) to reduce or eliminate actual or potential double taxation due to inconsistent treatment of transactions with cross-border impact—most conspicuously for transfer pricing matters, but potentially for other issues as well. As the… Read more »

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Understanding and Managing Privileges in Today’s Interconnected World
A complicated web of communications in a global world presents real-world challenges

Gone are the days when business and fashion trends developed regionally. Remember when certain clothing styles were unique to particular regions in the United States or to different countries? Or when certain foods were generally available only in certain parts of the world? Globalization has brought the world much closer… Read more »

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Expect More Civil Tax Penalties—So, Now What?
How to prepare for and defend against the more frequent penalties

Imagine a street with a twenty-five-mile-per-hour speed limit, but everyone knows the police don’t patrol the street. Would you go twenty-five miles per hour? In a voluntary tax system, the Internal Revenue Service enforces the Internal Revenue Code (IRC, or the Code) with the threat of the civil tax penalty.… Read more »

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When the IRS Says It’ll “Meet You in Paris”: Recent Trends & Developments in Outbound U.S. Exchange-of-Information Techniques
The FATCA rollout and other automatic EOI procedures mean that the IRS now has much more access to international tax information about U.S. taxpayers

The Internal Revenue Service is looking for your international tax data—that is, if the IRS doesn’t already have it. With the rollout of the Foreign Account Tax Compliance Act (FATCA) and other automatic exchange-of-information (EOI) procedures, the IRS is now receiving—and making use of—a large amount of international tax information… Read more »

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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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