Ask the Experts
The Tax and Other Costs of Paying Executives the Big Bucks
The Experts: Sheryl VanderBaan and Julie Collins
Tax reform legislation expanded the one-million-dollar annual deduction limitation applied to certain compensation paid to top executives of publicly held companies. The result? More disallowed compensation deductions for more companies and on more employees, a higher financial statement cost of compensation, and more work to account properly for the new… Read more »
Practical Insights for Combatting New York’s Expansion of Sales Tax Law
The Experts: Zach Gladney and Matthew Hedstrom
Much has been written about the New York State Department of Taxation and Finance’s positions on the taxation of software, software as a service (SaaS), and other software-based services. The critiques have concerned, in part, the department’s guidance on the sales and use tax consequences of cloud computing and other… Read more »
Refund Claims—Don’t Leave Money on the Table
The Expert: Rob Kovacev
Refund claims for open tax years are an often overlooked opportunity to ensure that a taxpayer takes advantage of tax benefits to which it is entitled. The recent tax reform legislation makes refund claims more valuable, particularly for tax benefits that will be reduced or eliminated beginning in 2018. It… Read more »
Elevating Examination Concerns Within the New LB&I
The Expert: Rosemary Sereti
For contentious U.S. federal tax issues, tax controversy management tends to follow a horizontal path from examination to appeals and finally litigation. The likelihood of being embroiled in a contentious issue increased recently as the Internal Revenue Service’s Large Business & International (LB&I) Division announced another round of campaigns. Campaign… Read more »
An End-of-Examination Checklist
The Expert: S. Starling Marshall
Nearing the end of an Internal Revenue Service exam cycle can feel like time to wrap up the process quickly and move on to the next task and then the next cycle. However, considering a few things to do now can result in a faster, more successful resolution of issues… Read more »
State Tax Matters for Foreign Corporations
The Experts: Maria Todorova and Eric J. Coffill
The Experts: Maria Todorova and Eric J. Coffill Even though state taxation has moved away from the worldwide unitary method, with Alaska being the only state currently requiring use of the worldwide unitary method and only then regarding oil and gas corporations, there are still many situations where non-U.S. companies… Read more »
Practical Implications of New Partnership Audit Rules
The Experts: Michael Hauswirth, Todd McArthur, and Adam Feuerstein
Ignore the new partnership audit rules at your own peril. Absent an election of earlier application, they take effect for tax years beginning in 2018. Under the new rules, the Internal Revenue Service (IRS) generally will collect tax at the partnership level on adjusted partnership items at the highest corporate… Read more »
Tax Reformers Consider Cash Flow Business Taxes, VATs, and Integration
The Expert: Harry L. (Hank) Gutman
In the last Congress, tax reformers considered cash flow business taxes, VATs, and integration as part of potential business tax reform. What’s the Outlook for Congressional Tax Reform? The second session of the last Congress saw some positive developments in the seemingly never- ending quest for business income tax reform.… Read more »
The New Partnership Audit Rules
The Expert: Kathryn Keneally
The Bipartisan Budget Act of 2015, signed into law November 2, 2015, repealed the long-standing audit and litigation procedures for partnerships that had been enacted in the Tax Equity and Fiscal Responsibility Act of 1982 and created a statutory framework for new partnership audit rules. The new partnership audit rules… Read more »
The IRS, Privilege, and Transparency
The Experts: Todd Welty, Mark Thomas, and Kevin Spencer
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… Read more »
Intangible Asset Valuation for Tax Purposes Under Fair Market Value and Arm’s-Length Standards Business transactions such as mergers, acquisitions, and business reorganizations often…
The New Corporate Alternative Minimum Tax: Five Not-So-Obvious Rule Applications to Consider Editor’s note: This article was written in mid-December 2022. It…
How Remote Workforce Programs Trigger Myriad Tax Problems—Part One Editor’s note: Given the complexity of this topic, this will…
Embracing ESG: Four Ways Tax Departments Can Add Value Environmental, social, and governance (ESG) considerations command a continually growing…
In Memoriam: Eric Lee Johnson The TEI community recently lost an amazing tax professional and…
How Remote Workforce Programs Trigger Myriad Tax Problems—Part Two The coronavirus pandemic created an explosion in remote workforce programs,…