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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 »
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 »
TEI Roundtable No. 41: Tax Insurance: An Agent of Change
It’s on the front burner these days
The tax insurance market is rapidly evolving and its benefits are becoming more widespread, especially in the area of mergers and acquisitions. To find out more about what’s happening in this space, we convened a roundtable comprising four knowledgeable professionals who gave us the real skinny on tax insurance: Jordan… Read more »
TEI Roundtable No. 40: Foreign Tax Credit Regulations
Are you up-to-date?
For almost four decades, the foreign tax credit regulations have established a three-part net gain requirement for determining when a particular foreign levy is an income tax. Now, things have changed. We assembled a panel of knowledgeable tax practitioners in the space to discuss how these changes came about and… Read more »
The Presumption of Correctness
A pesky problem in state tax law
A common question tax directors ask when considering whether to litigate a state tax case is, What is the likelihood we will win? It’s an obvious question to ask, but an impossible one to answer. In our own experience, we have won cases we’d thought were stacked against us and… Read more »
Technical Corrections to the 2021 Final Foreign Tax Credit Regulations
Correcting the uncorrectable?
As readers are well aware, almost a year ago, on December 28, 2021, the Treasury Department issued final foreign tax credit regulations (hereafter the “final regulations”)1 finalizing the proposed regulations that Treasury had issued the prior year.2 On July 26, 2022, Treasury issued two sets of technical corrections to the… Read more »
Managing Corporate Foundation Risk
What role do in-house tax professionals play in advancing charitable objectives?
Causes worthy of support are plentiful, and new ones seem to appear daily. How a company responds to societal needs is more important than ever. More than 2,800 corporate foundations are estimated to exist in the United States.1 Many companies are moving away from traditional or responsive models of philanthropy… Read more »
Tax Department of the Future: Reimagining Tax Technology On the first full day of TEI’s 75th Anniversary Celebration,…
State Tax Policy Takes Center Stage In an informative session on the first day of the…
The New Era of Transparency: Global Trends and Management Strategies In a particularly engaging session at TEI’s Annual Conference and…
TEI’s 75th Anniversary Celebration: A Closer Look & An Optimistic Future This past October, we took the opportunity to recognize a…
TEI Bestows President’s Award on Makaris and Wireman, Honorary Membership on Silbiger Two of the highest honors a TEI member can receive…
Global Tax Policy and Controversy Trends In an engaging and educational Annual Conference session moderated by…