There once was a time when a business’ headquarters location was based on proximity to natural resources and transportation networks. If you owned a mill, you worked near a river. If you exported goods, you were near a port. While some of those geographical limitations still exist, most businesses operating… Read more »
It’s late in the day. After weeks of review, it’s time to file an entity classification election for an entity in your company’s structure. The election is due today. You have already carefully analyzed the ramifications of the election. Form 8832 has been drafted, reviewed, and approved. All that is… Read more »
The IRS has imposed increasing disclosure demands on large, multinational taxpayers, requesting filing of a slew of additional documents and forms. Question: How will the Schaeffler case affect the IRS’ ability to require additional disclosure documents from taxpayers? Answer: In the last decade, the Internal Revenue Service (IRS) has shifted…
Many TEI members are acquainted with the IRS’s Office of Professional Responsibility (OPR) and Karen Hawkins, its director until just a few months ago. In the first day of her new life, Hawkins graciously agreed to talk to Tax Executive about her tenure at OPR and the impact of two…
It is an honor to serve as your international president. While it seems like only a short time ago that I received the happy news from Nominating Committee Chair Paul O’Connor that I had been nominated for TEI treasurer, almost four years have, in fact, passed. During that time, I have… Read more »
Let’s tell it like it is. The role of the corporate tax practitioner has changed dramatically in the last twenty years as the tax function has expanded in scope and responsibility. Not surprisingly, the status of the head of corporate tax has changed as well, and now more chief tax…
At the UNCC Accounting Scholarship Banquet on April 23, the TEI Carolinas Chapter awarded scholarships to five accounting students who attend universities in North and South Carolina. Among the recipients was University of North Carolina at Charlotte senior Jonathan Brown. Jonathan is majoring in accounting and currently interns in the tax…
Managing state tax controversies is a complex task that involves an understanding of substantive and procedural rules that vary significantly by jurisdiction. Part I of this article, published in the May/June issue of Tax Executive, explored considerations for selecting the best forum for litigation. Part II of this article addresses…
Corporate tax provisions* 5-year amount ($ billions) Deferral of active income of controlled foreign corporations $418 Deferral of gain on like-kind exchanges $68 Deduction for income attributable to domestic production activities $65.1 Exclusion of interest on public-purpose tax-exempt bonds $49.2 Tax credit for low-income housing $38.8 Individual provisions 5-year amount… Read more »
Transfer pricing. This is one of the most complex and controversial areas of corporate tax, occupying considerable time and energy on the part of many of TEI’s members, especially in the last twelve months. What exactly is transfer pricing? According to Mike Patton and Eric Ryan, partners at the law…
