Features

TEI Roundtable No. 4:
Insourcing vs. Outsourcing

Corporate tax practice is becoming more complicated, and the expectations placed on TEI members more demanding. So it’s not surprising that more corporate tax practices are considering or already outsourcing more tax functions. How do you make the decision to outsource, and what are the challenges facing those companies that… Read more »

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Transfer Pricing: Are We in a Global Tax War?
Expect Controversy To Heat Up in Light of BEPS

Transfer pricing. This is one of the most complex and controversial areas of corporate tax, occupying considerable time and energy on the part of many of TEI’s members, especially in the last twelve months. What exactly is transfer pricing? According to Mike Patton and Eric Ryan, partners at the law… Read more »

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VAT Extends Global Reach
Why Don’t We Have VAT in the U.S.?

Question: What do more than 160 countries have that the United States does not? Answer: A value-added tax (VAT) VAT is a broad-based consumption tax, chargeable at every stage of the supply chain, up to the retail stage, that generally allows the recovery of input tax for businesses and results… Read more »

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Latin America: Many Trading Partners, Diverse Tax Implications
Newest TEI Chapter Has Big Plans for 2015

In 2015, the vast majority of U.S. international companies have many markets to choose from, including China, India, Japan, Western Europe, Eastern Europe, Africa, and Canada. Increasingly, however, global firms are looking to market their products, invest in economies, engage in trade, or simply do business with countries in Latin America.… Read more »

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Procedural State Tax Issues: Part I
Finding the Best Forum

Managing state and local tax controversies is not an easy task. In addition to understanding the differences between the substantive laws applied in each jurisdiction, multistate taxpayers also need to understand the differences in procedural rules governing those disputes. In this two-part article, we address the most common issues that… Read more »

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TEI Roundtable No. 3:
The Changing Role of the Chief Tax Officer

The dizzying speed of technology, as software enables you to do your job not only quicker but more effectively. The expanding expectations of millennials, with their stated desire to better balance work and family. The burgeoning maze of regulations, with increasing government oversight. The globalization of the economy, as evidenced… Read more »

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FASB’S
Revenue Recognition Standard Takes Center Stage

The Financial Accounting Standard Board’s (FASB) long-anticipated new standard on revenue recognition is clearly one of the most important developments in US GAAP accounting in the last several years. John Hepp, partner in Grant Thornton’s National Professional Standards Group, calls the new revenue standard, issued in May 2014, “the most… Read more »

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Creative Approaches to Large-Case Tax Administration
IRS Budgetary Limitations Don’t Deter IRS from Precision, Speed, Transparency Goals

Despite budgetary and resource constraints at the Internal Revenue Service, corporate boards, securities regulators, and even the IRS are pressing to see increased transparency, greater speed, and enhanced precision on the part of large business taxpayers, according to KPMG tax professionals Mike Dolan and Tom Greenaway. Dolan is national director… Read more »

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Intercompany Transactions: Current State Tax Developments
Nexus and documentation are key issues in understanding the current intercompany transaction legal landscape

Intercompany transactions can be used to shift income from entities with a physical nexus in many states to a related member with a limited nexus in favorable taxing jurisdictions. In moving to combat the benefits received from such intercompany transactions, states tend to employ one or more of the following… Read more »

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LB&I Audits: Old Lessons, New Approach
Transparency, Collaboration, Fair and Efficient Resolution: No Argument with Goals, but the Devil Is in the Implementation Details

Those who ignore history are doomed to repeat it. That adage is true in all walks of life, but it is particularly appropriate as the IRS prepares to implement its most recent initiative for examinations by the Large Business & International division (LB&I), as described in the draft release of… Read more »

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