TEI Roundtable No. 26: Diversity & Inclusion
It’s essential in the corporate tax space
We’ve been conducting roundtables and conference sessions on diversity and inclusion for several years now—and for good reason. Simply put, the subject should be top of mind and a key agenda item for our members and their organizations. To check out what’s happening as we approach 2020, we convened a…
In 2020, New Tech Should Empower Tax Professionals, Not Replace Them
For many tax executives and finance professionals, 2019 has been the year that several emerging trends could no longer be denied. Yes, machine learning and artificial intelligence are automating many basic accounting functions. Yes, businesses worldwide are streamlining their workflows and integrating cloud-based services. And yes, customers and companies are… Read more »
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…
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…
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…
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.…
Korean Versus U.S. Tax Controversy Practice
The Expert: Michael Quigley
There are key differences between South Korean and U.S tax practices, which all professionals involved in a Korean subsidiary’s tax audit should note. Question: What’s the best way to manage your Korean subsidiary’s tax audit while avoiding frustration and surprise? After leading the tax controversy groups at two outstanding global law…
A Survival Guide for In-House Accountants
In-house accountants are understandably anxious about being caught in the crosshairs of technological change. After all, better software and improved machine learning are automating many basic accounting functions, and stricter managerial scrutiny has put many in-house teams in the unenviable position of having to defend the accuracy, efficiency, and value… Read more »
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…
On BEPS, Other International Issues
Deloitte released its 2019 BEPS and the Global Tax Reset Survey, which garnered responses from 405 people in 35 countries, most of whom carry the title of tax director or tax vice president for their organizations. Although some of the results were to be expected, such as that sixty-two percent… Read more »
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…
Prepare for Public Country-by-Country Reporting With public country-by-country reporting (CbCR) on the horizon, companies with…
Question: How Can Companies Take Advantage of Digital Assets With No Tax Impact? Digital-asset-based loyalty and reward programs allow companies to create a…
The Rise of the Excise Tax In August 2022, Public Law No. 117-169—commonly called the Inflation…
Who Is the Customer? Compared to the complexity of cost-of-performance (COP) sourcing of services…
Navigating Tax Risk in the Modern Era: Why Tax Technology Is Essential In today’s ever-changing tax world, managing the organization’s tax risk…