Cover
Tax Developments in 2016
Part 1: Federal Tax Developments Under Sections 385, 355, and 382; and new rules on partnership audits dominate landscape
This article reviews and analyzes recent law changes and IRS guidance for federal income tax issues this past year. Section 385 Proposed Regulations — Impact on Related-Party Financing Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify… Read more »
TEI Roundtable No. 10: Tax Plans of the Presidential Candidates
Shockingly (Haha), Clinton and Trump Proposals Differ Dramatically
This is not your typical presidential election season. So, as we prepare this issue of the magazine, tax issues are not on the front burner. Who knows what will happen during the debates or as the campaign heads inexorably toward Election Day? For this roundtable, we convened a group of… Read more »
Sauce for the Goose: Standards Applicable to Taxpayers, Practitioners — and the IRS
The contention among the parties results not from a lack of reasonable standards, but rather from an apparent failure by some IRS personnel to follow those standards in practice and the relative lack of accountability.
The relationship between the Internal Revenue Service’s Large Business & International (LB&I) Division and its constituent taxpayers is complex, marked by alternating episodes of cooperation and contention. LB&I often invites taxpayers and their representative groups to participate in the agency’s critical self-evaluation and listens closely to suggestions and complaints. At… Read more »
State Aid: What It Is, and How It May Affect Multinationals and Tax Departments
European Commission’s actions against member states bear close scrutiny
Never before has international taxation been in such a spotlight in the business press. Cross-border mergers, international tax policy, and base erosion and profit shifting (BEPS) have each been the subject of major front-page articles in the financial news. Over the last two years another topic has increasingly been in… Read more »
The New LB&I
Recent IRS reorganization raises panoply of significant issues
For a large majority of business taxpayers and their in-house tax professionals worldwide, the Large Business & International Division (LB&I) of the Internal Revenue Service (IRS) represents the principal point of regular interface with the U.S. taxing agency. Thus, any changes, whether large or small, in scope, focus, or operation… Read more »
AI in the Tax Department: Getting Tax a Seat at the Table Artificial intelligence (AI) is reshaping business functions rapidly, yet many…
Planning for IRS Audits in an Era of Uncertainty In its ongoing crusade against so-called “basis-shifting” transactions, the Internal…
Transfer Pricing and Valuation in Financial Transactions Business transactions such as mergers, acquisitions, and reorganizations often necessitate…
TEI Roundtable No. 53: Using AI for Tax Law Research As artificial intelligence continues its scorching rise, in-house tax professionals…
Andreia Verissimo Andreia Verissimo, the senior manager for US tax policy at…
TEI Roundtable No. 52: FASB Accounting Standards Update 2023-09—Income Taxes (Topic 740) As financial reporting evolves, the Financial Accounting Standards Board (FASB)…