Ask the Experts

IRS Transcripts
The Experts: Alina Solodchikova, Mary Slonina, and Whitney Brady

Internal Revenue Service tax transcripts can be a valuable tool when a tax professional is amending a tax return, filing a tentative claim for refund, verifying entity elections, tracking payments and credits, monitoring the IRS’ processing of filings, and determining information about an entity, like its filing status and the… Read more »

Uncertain Times, Uncertain Costs: Deducting Expenditures Subject to Pending Insurance Claims
The Experts: Lee Kelley, Kandyce Korotky, and Jeffrey Zink

With the global pandemic COVID-19 upending business operations worldwide, companies are incurring unexpected—and often large—costs. Some of these costs may ultimately be covered by insurance. Given the unprecedented circumstances, however, there are bound to be questions and disagreements about which of those costs are covered by companies’ insurance policies. When… Read more »

RPA, DLT, ML, and AI: The New Normal in the Tax Function
The Expert: Anli Chen

As recently as five years ago, technologies such as robotic process automation (RPA), distributed ledger technology (DLT), machine learning (ML), and artificial intelligence (AI) were mere technology buzzwords for most tax professionals. Now, rarely do you see an organization that is not incorporating these technologies into its strategic plan for… Read more »

Digital Tax
The Experts: Kathrine Kimball, Sofie Stas, and Su Merck

Question: Why should a “non-digital-born” company be concerned about digital tax? It’s a valid question. Many taxpayers that operate in traditional, supply-chain-based business models rightfully tuned out of the Organisation for Economic Co-operation and Development’s (OECD’s) earliest discussions of digital tax, thinking it was exclusively for “digital-born” taxpayers. However, the… Read more »

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… Read more »

10 Best Practices for Unclaimed Property Compliance
The Expert: Michelle Moloian

Unclaimed property compliance reporting requirements may seem simple to some tax practitioners, but the lack of proper historical documentation can cause problems during an audit. Question: How can companies ensure they are in compliance with unclaimed property reporting requirements? Answer: On the surface, unclaimed property (UP) compliance reporting seems straightforward.… Read more »

Cost-of-Performance Versus Market-Based Sourcing
The Expert: Jamie Yesnowitz

Calculating how to source sales to determine a company’s state corporate income tax sales factor (and overall apportionment factor) drives how much that company ultimately will pay in tax to the states. The basis of the economy has shifted over time from the sale of goods toward the sale of… Read more »

The New Front Line: Transaction Taxes on Services
The Expert: David A. Fruchtman

In South Dakota v. Wayfair, Inc.,1 the U.S. Supreme Court cleared a path for states to impose sales and use tax collection and remittance obligations on out-of-state businesses lacking physical presence within the state. Notably, the Court’s decision applies to all subnational transaction taxes. Moreover, in the decision the Court… Read more »

Practical Application of Constitutional Limitations: A Road Map to Future Success
The Experts: Craig B. Fields, Mitchell A. Newmark, and Eugene J. Gibilaro

In the wake of the U.S. Supreme Court’s decision in South Dakota v. Wayfair, Inc., taxpayers have sought practical approaches to challenges under the significant remaining constitutional limitations on the authority of states to tax interstate commerce. In Wayfair, the U.S. Supreme Court put two large stakes in the ground.… Read more »

Getting Your Refund—Once Your Tax Disputes Are Resolved: Navigating the Joint Committee Review Process
The Expert: Marjorie Margolies

If you are like most taxpayers, you want to close out your old tax years as soon as possible, especially when you are owed a refund. In many cases—refund or not—there are a surprising number of Internal Revenue Service procedures and documentation requirements to navigate after resolving or settling the… Read more »

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