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Tax Rate Modeling in the New World of US International Tax
Foreign branch versus CFC and the GILTI high-tax exclusion are two essential modeling imperatives
The world is getting smaller and more complex. National economies are more integrated globally, but national deficits and the need for tax revenues are driving unilateral measures. The original objective of the base erosion and profit shifting (BEPS) project has been described as ensuring that profits are taxed where economic… Read more »
The Pandemic’s Effect on Sales Tax Post-Wayfair
Expect even more uncertainty going forward
The COVID-19 pandemic has wrought disruption and change in practically every area in which we operate, and its effects on the sales tax environment are no different. What is particularly interesting about the operation of the sales tax is that states and businesses are still grappling with the groundbreaking developments… Read more »
Understanding the Built-in Gain and Loss Rules of Section 382—and Possible Significant Changes on the Horizon
Unprecedented NOLs have accompanied unprecedented times
As we all welcome the new year, companies look forward to the future and hope to leave 2020 to the history books. Because of the lingering economic effects of COVID-19 and the expansion by the Tax Cuts and Jobs Act (TCJA) of the application of the Section 168(k) first-year bonus… Read more »
More Transparency in the EU: Questions & Answers on DAC 6
Are you up to date on cross-border arrangements?
The European Union (EU) passed a sixth version of its Directive on Administrative Cooperation in the Field of Taxation, known as DAC 6 (EU Council Directive 2018/822), on May 25, 2018. DAC 6 introduces reporting requirements for professional intermediaries (and, under certain circumstances, taxpayers) relating to their involvement in a… Read more »
Procurement and Tax—Time to Integrate
Why implementing a third-party tax engine is the best approach
One of the most important functions at which companies must excel is selling goods and services with as little transactional friction as possible—particularly in today’s world of digital commerce. Companies invest significant effort in the sales environment, but an equally necessary value-add for tax is the ability to purchase goods… Read more »
There’s a Mistake on Your Tax Return—Should You Fix It?
Check out this proposed framework for overall compliance
This article proposes a framework for deciding whether to fix a mistake found on a previously filed tax return. Rather than treating mistakes on previously filed tax returns as isolated events to be managed on an ad hoc basis—the usual and less effective approach—the proposed framework views the discovery of… Read more »
OECD Races Toward Completing Final Report on Digital Economy
But two fundamental “pillars” present structural challenges
The Organisation for Economic Co-operation and Development (OECD) is racing toward meeting an ambitious target by the end of the year that could radically change the way all multinational enterprises (MNEs) are taxed. The target—a final report—was set forth in January 2019 under the cover of addressing the digital economy.1… Read more »
Deftly Navigating an MTC Audit: Considerations for Taxpayers
Check out this stat: In the last three years, the MTC Audit Program has recommended state tax assessments in excess of $45 million annually
As recently recognized by Tax Analysts, the Multistate Tax Commission (MTC) has been gaining in prominence and, arguably, effectiveness.1 One of the MTC’s several activities is to administer audits on behalf of states. The MTC’s Joint Audit Program (Audit Program) is authorized by the Multistate Tax Compact and was initiated… Read more »
A More Collaborative Tax Controversy Approach?
Strategies for Exam and Appeals
Tax executives are familiar with the scenario: Internal Revenue Service examiners are in the building and are beginning to issue information document requests (IDRs) on routine and sensitive issues. One typical taxpayer response is to go on the defensive. This approach includes not voluntarily identifying issues and transactions; responding to… Read more »
A Tax Executive’s Guide to Spin-offs: 10 Things You Won’t See in Section 355
Advise board and officers to be careful about certain negotiations or public statements during pendency of the spin
Behind the closed doors of a corporate boardroom somewhere in America, the directors of a publicly traded company are discussing the future of their business. For many years, the company has operated two major divisions that have gradually diverged over time. These divisions (having the remarkably original names Business A… 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…