Federal Tax
Presto Change-o: Unwinding Transactions in the Face of Uncertainty
It’s all about the rescission doctrine
With tax reform on the horizon, many companies are actively considering how the various proposals could impact their business and how they should structure their operations. However, many companies do not want to go all in and pull the trigger on a transaction based on what may amount to an… Read more »
Effective NOL Planning in Light of Tax Reform
Can your company unlock the value of net operating loss carryforwards to reduce future taxable income?
Under current tax rules, a corporation can generally carry back a net operating loss (NOL) to the two preceding taxable years and carry it forward up to the twenty taxable years following the loss to offset 100 percent of federal taxable income and ninety percent of the alternative taxable income.… Read more »
Section 199 and Cloud Software: Clearing the Fog
Are you up-to-date on current Treasury regs?
The domestic production activity deduction under Section 199 of the Internal Revenue Code of 1986, as amended (hereinafter “Section 199”), provides a deduction equal to nine percent of the lesser of taxable income or income attributable to certain qualified production activities. For the 2016 fiscal year, this deduction was estimated… Read more »
Congress Pivots From Health Care to Tax Reform
Ultimate outcome on taxes in 2017 still up in the air
Benjamin Franklin is frequently credited with saying that there’s nothing certain in life except death and taxes. I would suggest an addendum to this adage for 2017: another certainty is the steady drumbeat of news stories claiming that tax reform is imperative and imminent. Years of hearings, commissions, white papers,… Read more »
The Burgeoning Importance of E-Invoicing Although the United States has not yet officially adopted e-invoicing,…
The Presumption of Correctness A common question tax directors ask when considering whether to…
Technical Corrections to the 2021 Final Foreign Tax Credit Regulations As readers are well aware, almost a year ago, on…
TEI Roundtable No. 40 Foreign Tax Credit Regulations For almost four decades, the foreign tax credit regulations have…
Reconnecting at TEI’s Annual Conference I am very excited about TEI’s 77th Annual Conference, as…
Steve Saunders Steve Saunders gained an appreciation of the complexity of tax…