Features
Altera Deconstructed: A Nuanced Alteration in Tax Law
Tax Court’s Unanimous Opinion Deals With Unusual Regulatory Situation
On July 27, the Tax Court issued a unanimous opinion1 in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), in which the court held that Treas. Reg. § 1.482-7(d)(2) is invalid. It is relatively rare for a court to invalidate Treasury regulations, and, for that reason alone, the decision… Read more »
Are You Considering an Advance Pricing Agreement?
Companies Need To Conduct Benefit Analysis To Determine If APA Is Best Approach
In 1991 the Internal Revenue Service (IRS) established the Advance Pricing Agreement (APA) program, allowing a taxpayer to request that the IRS, and potentially other countries, prospectively approve its transfer pricing facts, transfer pricing methodology, and arm’s-length range of results. The certainty provided by this prospective approach, combined with the… Read more »
The OECD’s BEPS Final Report
Part I: Introduction and Background 15 Actions, Dozens of Questions Maybe the anticipation didn’t reach that of ardent fans waiting for the trailer to the next Star Wars movie. And maybe it didn’t rival that of passionate followers of Harry Potter breathlessly lining up at midnight to make sure they… Read more »
The Trials and Tribulations of the Family Office
Get ready to deal with the trappings of wealth and leveraging the next generation’s tax exemptions
If you’re a veteran family office adviser, you’ve spent decades working with the family’s estate-planning counsel to ensure that wealth is passed to succeeding generations as tax efficiently as possible. You faithfully oversee the implementation of annual exclusion gifts, intrafamily loans, and rolling grantor-retained annuity trust (GRAT) programs, and you… Read more »
Roundtable No. 6 The Evolving Role of the Chief Financial Officer
As Compliance, Reporting, and BEPS Become More Complicated, so Does the Role of the CFO
Channeling Kevin Bacon in the movie A Few Good Men, these are the facts, and they are indisputable: As the role of the chief tax officer (CTO) becomes geometrically more complex (see Roundtable No. 5, September/October 2015 issue of Tax Executive), so does that of the chief financial officer (CFO).… Read more »
How To Bind Without Getting in One: Avoiding Controversy Over Signature Authority Issues
It’s late in the day. After weeks of review, it’s time to file an entity classification election for an entity in your company’s structure. The election is due today. You have already carefully analyzed the ramifications of the election. Form 8832 has been drafted, reviewed, and approved. All that is… Read more »
The Impact of Loving and Ridgely on Corporate Tax Practice
Former OPR Director Reflects on Her Tenure at the IRS
Many TEI members are acquainted with the IRS’s Office of Professional Responsibility (OPR) and Karen Hawkins, its director until just a few months ago. In the first day of her new life, Hawkins graciously agreed to talk to Tax Executive about her tenure at OPR and the impact of two… Read more »
TEI Roundtable No. 5: Corporate Structure and the Evolving Tax Function
As the Tax Role Elevates in Importance, So Does Status in Corporate Hierarchy
Let’s tell it like it is. The role of the corporate tax practitioner has changed dramatically in the last twenty years as the tax function has expanded in scope and responsibility. Not surprisingly, the status of the head of corporate tax has changed as well, and now more chief tax… Read more »
Forging Forward — But How Fast and in Which Direction?
Data rules the tax technology roost, elevating professionals who embrace its potential, but the “new normal” is not without its pitfalls
In the world of real estate, it’s all about location, location, and location. In the tax world, it is becoming all about data, data, and data. And whatever facet of tax technology you’re talking about—whether it’s hardware, software, Big Data, the cloud, data storage, or cybersecurity—the data are the key drivers.… Read more »
Procedural State Tax Issues: Part II
Coordinating Multistate Litigation
Managing state tax controversies is a complex task that involves an understanding of substantive and procedural rules that vary significantly by jurisdiction. Part I of this article, published in the May/June issue of Tax Executive, explored considerations for selecting the best forum for litigation. Part II of this article addresses… Read more »
State and Local Tax Implications for a Remote Workforce State and local tax issues related to remote workforces have…
Tax’s Role in Tech Transformation As tax experiences its own transformation with technology, companies are…
Key Challenges and Opportunities for Tax Directors in a Tightening Economy Navigating a tightening economic cycle—characterized by prolonged high interest rates…
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…
TEI Roundtable No. 48: AI Implementation in Today’s Tax Landscape As artificial intelligence (AI) gains traction throughout the business world,…