Features
Buying and Selling CFCs Under New Corporate Alternative Minimum Tax Regime
Statute may prove expensive and cumbersome
As part of the Inflation Reduction Act, Congress enacted a new corporate alternative minimum tax (CAMT) that may prove both expensive and cumbersome for large multinationals. Added to the insult of the minimum tax that must be paid is the injury of a rude awakening: that tax professionals can no… Read more »
Market Sourcing or Bust: The Kitchen Sink Approach of COP-Sourcing States
The binary nature of the determination makes COP sourcing controversial
The division of multistate business income among the states is accomplished through formulary apportionment. State formulary apportionment provisions increasingly rely on the receipts factor to divide income, sharpening the focus on the sourcing of receipts. Although many states have transitioned to a market-sourcing (also known as destination sourcing) approach, historically… Read more »
TEI Roundtable No. 42: A Deep Dive Into the Murky Waters of UTPs
Uncertain tax positions (UTPs) offer taxpayers both opportunities and challenges. We wanted to take a closer look at this important issue, so, of course, we assembled a roundtable of knowledgeable tax professionals, including George Clarke, partner at the Washington, D.C., office of Baker McKenzie; George Hani, member with Miller &… Read more »
How Remote Workforce Programs Trigger Myriad Tax Problems—Part Two
Analyzing taxable presence and nexus issues for employers
The coronavirus pandemic created an explosion in remote workforce programs, some temporary but others indefinite or permanent. Remote work situations can arise in a wide range of settings—some are planned, and others arise well after the fact as a surprise to the in-house tax team. One critical tax issue introduced… Read more »
GloBE Meets GILTI—Part Two
What’s the status of implementation?
Our article, “GloBE Meets GILTI,” which appeared in the January/February issue of Tax Executive, addressed how taxes on global intangible low-taxed income (GILTI) might be allocated. Sadly, the story was already out of date by publication. This follow-up article addresses not the possibilities, but rather what the Organisation for Economic… Read more »
TEI Diversity, Equity, & Inclusion Survey Results
Uncovering root challenges in recruiting and retaining talent
The many benefits of a diverse and inclusive workplace include increased revenue, improved employee engagement, and more innovation. Despite the great strides that have been made in driving awareness of the importance of diversity, equity, and inclusion (DEI) in the workplace, much work still needs to be done within the… Read more »
The New Corporate Alternative Minimum Tax: Five Not-So-Obvious Rule Applications to Consider
Like it or not, the CAMT rules have unexpected applications and potentially problematic effects
Editor’s note: This article was written in mid-December 2022. It is expected that by the time of publication, the US Department of Treasury and the Internal Revenue Service may release guidance to address some issues this article discusses. The corporate alternative minimum tax (CAMT) was enacted as part of the… Read more »
Intangible Asset Valuation for Tax Purposes Under Fair Market Value and Arm’s-Length Standards
Some differences between the two approaches
Business transactions such as mergers, acquisitions, and business reorganizations often require valuations of intangible assets. Applying different standards may result in different valuations for the same intangible asset. It is therefore important to identify the appropriate valuation standard before attempting any valuation of an intangible asset. Significant differences may arise… Read more »
Embracing ESG: Four Ways Tax Departments Can Add Value
Leaving tax departments out of the discussion is unfortunate—and often costly
Environmental, social, and governance (ESG) considerations command a continually growing share of attention in organizations of all types as various stakeholder groups sharpen their focus on sustainability, equity, and accountability. Today more and more investors, consumers, and employees make decisions based on an organization’s ESG strategy, policies, and actions. As… Read more »
How Remote Workforce Programs Trigger Myriad Tax Problems—Part One
What’s triggered? How about fringe benefits, federal and state tax withholding, and information-reporting issues?
Editor’s note: Given the complexity of this topic, this will be a two-part article. This first part addresses fringe benefits, federal and state tax withholding, and information reporting. The second part, which will appear in the May-June issue of Tax Executive, will address 1) tax reporting and withholding under remote-work… Read more »
Tax Department of the Future: Reimagining Tax Technology On the first full day of TEI’s 75th Anniversary Celebration,…
State Tax Policy Takes Center Stage In an informative session on the first day of the…
The New Era of Transparency: Global Trends and Management Strategies In a particularly engaging session at TEI’s Annual Conference and…
TEI’s 75th Anniversary Celebration: A Closer Look & An Optimistic Future This past October, we took the opportunity to recognize a…
TEI Bestows President’s Award on Makaris and Wireman, Honorary Membership on Silbiger Two of the highest honors a TEI member can receive…
Global Tax Policy and Controversy Trends In an engaging and educational Annual Conference session moderated by…