Features

The Global Tax Information Age
International exchange of info growing—but still room for development

For years, governments around the world have called for changes to tax administration to prevent abusive tax avoidance and tax evasion. The need for change has been driven in part by the increasingly globalized economy, where cross-border activities and transactions are the norm rather than the exception. The Organisation for… Read more »

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Tales From the California Tax Controversy Trenches: Navigating FTB Sales Factor Audits
Proper planning can lead to a successful audit— or at least a more tolerable one

One of the California Franchise Tax Board’s1 guiding principles is to “administer the Revenue and Taxation Code . . . and be vigorous in requiring compliance with the law.”2 Our decades-long experience with California tax controversy provides perspective on the FTB’s vigor for compliance. This vigor is never more apparent… Read more »

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TEI Roundtable No. 35: Enforcement in 2021—and Beyond
What can taxpayers realistically expect?

There’s a new sheriff in D.C., but what does that mean for taxpayers in terms of enforcement? That’s a difficult question. As you might expect, we convened a roundtable of some of the most notable forecasters in the tax space to discuss this issue, including Brad Pees, lead tax controversy… Read more »

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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 »

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Searching for Shangri-La: Reflections on the OECD’s Digital Tax Project
Analysis begins and ends with discussion of twin pillars

The goal of rewriting international tax rules to adapt more fully to the digitizing economy has eluded policymakers over the past decade. Efforts to find an acceptable solution at the global level so far have failed to muster consensus as different constituencies have raised perceived shortcomings that have halted progress,… Read more »

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TEI Roundtable No. 34: International Tax Issues and the Global Pandemic

No area of tax has escaped the influence of the global pandemic, and that certainly includes international tax, the theme of this issue of Tax Executive. But what exactly has the impact of COVID-19 been, and what is likely to be its impact throughout 2021? To take a deeper dive… Read more »

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Global Mobility During a Pandemic
Workforce issues take center stage

The COVID-19 pandemic has disrupted how US businesses operate, causing significant challenges as many seek to adapt to a harsh economic reality that has continued into 2021. As businesses navigate the crisis, they have managed a seismic shift in how American and global workforces operate that has disrupted and redefined… Read more »

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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 »

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A Major Development in Corporate Income Tax
What’s New Hampshire v. Massachusetts got to do with it?

The pandemic has caused drastic shifts in employment and business arrangements. Major tax implications have surfaced, and taxpayers have been eager for state guidance or federal legislation to address pandemic-related issues. But with limited state guidance, and with federal legislation completely stalled, one development has become the focus of our… Read more »

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Top State Tax Policies You Can Expect to Deal With in 2021
Fiscal fallout from the pandemic takes hold

When states began their 2021 fiscal year budget processes in early 2020, just about every state anticipated revenue growth consistent with what it had seen in recent years. Most states had robust rainy-day funds, and some were looking at options to lower taxes. As we fast-forward to early 2021, few… Read more »

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