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You’ve Been Served: Defending Against a State Tax Class Action
Are you prepared for this rising threat to your business?

An email comes from the general counsel: your company has been sued by a customer who alleges that the company systematically overcharges sales tax.1 The complaint—the legal document that starts the lawsuit—contains multiple counts for various violations of state statutes and common law doctrines and demands damages, attorney’s fees, and… Read more »

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Are There Any Tax Incentives Left for the Energy Industry?
Let’s face it—multiple challenges confront the industry

The US energy industry has faced many challenges in its history, from boom-and-bust oil prices to pressures from overseas oil producers to domestic government regulations. Today the industry continues to confront its share of challenges, including pressures to transition from fossil fuels to alternative renewable energy sources such as wind,… Read more »

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Tips From The Art of War to Help in Your Research Credit Battle
Some may consider the IRS a nemesis, but your battle may be gathering the necessary data and documentation to calculate and support the credit

The legendary ancient Chinese general Sun Tzu has influenced Eastern and Western military thinking, coaching strategy, and now research tax credits.1 Some may consider the Internal Revenue Service a nemesis, but perhaps your own battle is to gather the necessary data or documentation to calculate and support the credit. To… Read more »

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New Frontiers of Dispute Settlement in a Pillar One World—Part Two
The success of Pillar One largely depends on the effectiveness of dispute settlement disciplines

Part One of this article, which appeared in the March/April 2022 issue of Tax Executive, discussed the evolution of the international tax system leading up to the modern proposal to implement an OECD-championed multilateral tax treaty to bring order to an increasingly complicated and digitized world. The recent impetus to… Read more »

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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 »

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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 »

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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 »

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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 »

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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 »

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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 »

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