Features
TEI Roundtable No. 42: A Deep Dive Into the Murky Waters of UTPs
Uncertain tax positions (UTPs) offer taxpayers both opportunities and challenges. We wanted to take a closer look at this important issue, so, of course, we assembled a roundtable of knowledgeable tax professionals, including George Clarke, partner at the Washington, D.C., office of Baker McKenzie; George Hani, member with Miller &… Read more »
How Remote Workforce Programs Trigger Myriad Tax Problems—Part Two
Analyzing taxable presence and nexus issues for employers
The coronavirus pandemic created an explosion in remote workforce programs, some temporary but others indefinite or permanent. Remote work situations can arise in a wide range of settings—some are planned, and others arise well after the fact as a surprise to the in-house tax team. One critical tax issue introduced… Read more »
GloBE Meets GILTI—Part Two
What’s the status of implementation?
Our article, “GloBE Meets GILTI,” which appeared in the January/February issue of Tax Executive, addressed how taxes on global intangible low-taxed income (GILTI) might be allocated. Sadly, the story was already out of date by publication. This follow-up article addresses not the possibilities, but rather what the Organisation for Economic… Read more »
TEI Diversity, Equity, & Inclusion Survey Results
Uncovering root challenges in recruiting and retaining talent
The many benefits of a diverse and inclusive workplace include increased revenue, improved employee engagement, and more innovation. Despite the great strides that have been made in driving awareness of the importance of diversity, equity, and inclusion (DEI) in the workplace, much work still needs to be done within the… Read more »
The New Corporate Alternative Minimum Tax: Five Not-So-Obvious Rule Applications to Consider
Like it or not, the CAMT rules have unexpected applications and potentially problematic effects
Editor’s note: This article was written in mid-December 2022. It is expected that by the time of publication, the US Department of Treasury and the Internal Revenue Service may release guidance to address some issues this article discusses. The corporate alternative minimum tax (CAMT) was enacted as part of the… Read more »
Intangible Asset Valuation for Tax Purposes Under Fair Market Value and Arm’s-Length Standards
Some differences between the two approaches
Business transactions such as mergers, acquisitions, and business reorganizations often require valuations of intangible assets. Applying different standards may result in different valuations for the same intangible asset. It is therefore important to identify the appropriate valuation standard before attempting any valuation of an intangible asset. Significant differences may arise… Read more »
Embracing ESG: Four Ways Tax Departments Can Add Value
Leaving tax departments out of the discussion is unfortunate—and often costly
Environmental, social, and governance (ESG) considerations command a continually growing share of attention in organizations of all types as various stakeholder groups sharpen their focus on sustainability, equity, and accountability. Today more and more investors, consumers, and employees make decisions based on an organization’s ESG strategy, policies, and actions. As… Read more »
How Remote Workforce Programs Trigger Myriad Tax Problems—Part One
What’s triggered? How about fringe benefits, federal and state tax withholding, and information-reporting issues?
Editor’s note: Given the complexity of this topic, this will be a two-part article. This first part addresses fringe benefits, federal and state tax withholding, and information reporting. The second part, which will appear in the May-June issue of Tax Executive, will address 1) tax reporting and withholding under remote-work… Read more »
The “Most Interesting Man in the World” of R&D Tax Credits
Using Dan’s technology tips to improve your process today
Remember the Dos Equis beer ads where a bearded, distinguished-looking older gentleman wrestled bears, had drinks with Castro, and climbed Everest with his mom on his back as the bombastic voiceover recounted his daring exploits? “Bear hugs are what he gives bears. He lives vicariously through himself. His mom has… Read more »
Apportionment: Normal Formulas Are Unfair and Can Be Challenged
Let’s acknowledge that companies’ advantages in the market arise partly from their human capital and use of assets—both tangible and intangible
For the 2022 tax year, of the forty-five states (plus the District of Columbia) that impose a corporate income tax, more than thirty require the use of a single sales factor normal apportionment formula; and, when we also consider states that put additional weight on the sales factor, that number… 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,…