Features

Oops! I Did It Again: Practical Implications of Revenue Procedure 2022-39
Regardless of how errors occur, they must be dealt with

A fact, well known in the tax community: every tax return contains at least one error. Except for the simplest Form 1040, this statement is invariably true, especially considering the increasing complexity of corporate returns.1 First, what is meant by an “error” on a tax return? No definition exists in… Read more »

TEI Roundtable No. 43: Separate, Combined, and Worldwide Unitary State Filings
Some practical advice for making these key decisions

One of the most talked-about education sessions at this year’s Midyear Conference in March was the session titled “Separate, Combined, and Worldwide Unitary State Filings—What’s New?” We thought this very important state and local tax topic deserved more discussion, so we convened a roundtable in May to take a deeper… Read more »

Buying and Selling CFCs Under New Corporate Alternative Minimum Tax Regime
Statute may prove expensive and cumbersome

As part of the Inflation Reduction Act, Congress enacted a new corporate alternative minimum tax (CAMT) that may prove both expensive and cumbersome for large multinationals. Added to the insult of the minimum tax that must be paid is the injury of a rude awakening: that tax professionals can no… Read more »

Market Sourcing or Bust: The Kitchen Sink Approach of COP-Sourcing States
The binary nature of the determination makes COP sourcing controversial

The division of multistate business income among the states is accomplished through formulary apportionment. State formulary apportionment provisions increasingly rely on the receipts factor to divide income, sharpening the focus on the sourcing of receipts. Although many states have transitioned to a market-sourcing (also known as destination sourcing) approach, historically… Read more »

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 »

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