Features
Much Ado, but Little New: A Guide to Section 951(a) After Build Back Better
What are the ramifications of Congress’ proposal?
The definition of “pro rata share” in Section 951(a)(2) is fundamental to the subpart F regime. That regime, of course, dates to the John F. Kennedy administration.1 Most words in current Section 951(a)(2) do, too. Though Congress amended Section 951(a)(1) on numerous occasions, it has left undisturbed the words of… Read more »
Disrupting the Norm: Using Technology to Reinvent State Tax Compliance
It’s time to free up capacity and deal with remote work
In the current business environment, the only constant in the face of major economic and societal shifts is dynamic change. As companies forge ahead, their tax departments increasingly lead the way in sustainably transforming their business models and their digital and strategic footprints. Tax leaders are remaking their technology infrastructures… Read more »
Obtaining IRS Refunds: Procedures and Strategies
It’s rarely as simple as you think
Uncertainty in tax law is reaching unprecedented levels. In the past four years, taxpayers have managed dramatic tax reform, pandemic-fueled emergency tax legislation, rafts of new Treasury Regulations (and accompanying challenges to some regulations), and increased aggressiveness by certain tax authorities. Tax departments now must be nimbler than ever as… Read more »
New Frontiers of Dispute Settlement in a Pillar One World—Part One
We’re witnessing an increased convergence of tax and trade in corporate risk management
Over the past several decades, the seemingly discrete disciplines of international tax and trade have become increasingly aligned as the globalization of corporate supply chains and the proliferation of online sales have accelerated. With this development, relations between the general counsel’s office and corporate tax departments have expanded. Corporate counsel… Read more »
TEI Roundtable No. 37: Lessons Learned From TCJA Implementation
What are the implications for Biden’s proposals?
This roundtable was conducted on October 27 as the closing plenary session of TEI’s 76th Annual Conference in Florida. The session, Lessons Learned From TCJA Implementation and Implications for Biden’s Proposals, featured four distinguished panelists who shared their perspectives on the practical implementation and administration of business tax reform legislation:… Read more »
Government Aid Disclosure—Spotlight on the CARES Act
What accounting rules and guidance did companies follow to report receipt of government aid?
The United States has spent more government aid to combat the COVID-19 pandemic than at any other time in the country’s history. Due largely to pandemic spending, the United States federal government debt increased from $22.7 trillion to $28.5 trillion in the past two years, with much of the increased… Read more »
The Evolving Landscape of Cross-Border Tax Examination
Critical strategies for tax departments to consider and pitfalls to avoid in the complex landscape of foreign tax audits
Our clients and our practice group members are increasingly occupied (and preoccupied) not only with challenges from the Internal Revenue Service but also with audit and enforcement actions from foreign tax authorities. In a world where many jurisdictions are increasingly hungry for tax revenues, the foreign subsidiaries of large multinationals… Read more »
Why Unclaimed Property Risk Management Is on the Menu in 2022
For certain states, unclaimed property represents a significant revenue source
Every state has adopted an unclaimed property (or escheat) law, which generally provides that a holder of unclaimed property must escheat the property to the state after it has remained unclaimed by its owner for a certain period (usually three or five years). The unclaimed property is the legal obligation… Read more »
Protecting Privilege in ‘Work From Anywhere’ Era
The move toward remote or hybrid work arrangements is underway and irreversible
Even prior to the COVID-19 pandemic, tax functions were adapting and reacting to fundamental change and uncertainty. Whether the changes were brought about by the Tax Cuts and Jobs Act, by ever more aggressive positions taken by state and local auditors, by complex and burdensome reporting regimes, by novel taxes… Read more »
Presto Change-o: Unwinding Transactions in the Face of Uncertainty
It’s all about the rescission doctrine
With tax reform on the horizon, many companies are actively considering how the various proposals could impact their business and how they should structure their operations. However, many companies do not want to go all in and pull the trigger on a transaction based on what may amount to an… Read more »
Prepare for Public Country-by-Country Reporting With public country-by-country reporting (CbCR) on the horizon, companies with…
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…
Who Is the Customer? Compared to the complexity of cost-of-performance (COP) sourcing of services…
Optimizing Your Tax and IT Stack Tax leaders, tax technologists, chief financial officers (CFOs), and chief…
Navigating Tax Risk in the Modern Era: Why Tax Technology Is Essential In today’s ever-changing tax world, managing the organization’s tax risk…