Tax Administration

ESG Tax Transparency
You might want to check out BRT’s statement signed by 181 CEOs

In years gone by, business looked primarily to increasing shareholder returns, paying less attention to how their business practices affected the environment and society. For many, the primary concern in supply chain design was cost, with little inquiry into how supply chain partners conducted business. But more and more, such… Read more »

Under the Radar: Employee Benefit Developments in 2020
And, believe it or not, they’re 𝘯𝘰𝘵 COVID-related

The story of the year has been the coronavirus. COVID-19 has dominated news headlines, social media, and virtually every aspect of our lives. The virus has likewise dominated legal and tax news. Lawmakers and agencies have enacted multiple pieces of legislation and other guidance to help employers navigate the changes… Read more »

Chapter 11 Corporate Bankruptcy Reorganizations and Tax Controversy: A Primer
The considerations: preparation of tax liability schedules, objections to IRS claims, expedited audits, IRS Appeals, potential tax liens, and choosing a forum for potential litigation

In direct response to the financial pressures caused by the coronavirus, many companies, including Gold’s Gym, Neiman Marcus, J.C. Penney, and Hertz, have filed voluntary Chapter 11 bankruptcy petitions in 2020.1 Others are contemplating doing the same. For entities saddled with debt, Chapter 11 of the Bankruptcy Code can offer… Read more »

There’s a Mistake on Your Tax Return—Should You Fix It?
Check out this proposed framework for overall compliance

This article proposes a framework for deciding whether to fix a mistake found on a previously filed tax return. Rather than treating mistakes on previously filed tax returns as isolated events to be managed on an ad hoc basis—the usual and less effective approach—the proposed framework views the discovery of… Read more »

COVID-19 Disruption: Challenges for Life Sciences Companies (and Beyond)
Cash flow strategies are paramount, then come “postscript” considerations

The COVID-19 pandemic has had an unprecedented impact on the business community. The life sciences industry has not been immune to its effects, since the pandemic has affected consumer demand for life sciences products in sometimes unpredictable ways and has wreaked havoc on supply chains. Although some life sciences companies… Read more »

Road Map to a Transfer Pricing Controversy
Preparing for success in audits and litigation in a strict enforcement environment

In recent decades, the Internal Revenue Service has pursued numerous long-running and complex transfer pricing audits. Although many have been resolved administratively, or prior to trial, the IRS has a decidedly uneven record in its litigation of high-profile transfer pricing disputes, not infrequently finding itself in the loss column in… Read more »

The Research & Experimentation Credit: New Issues on the Horizon
Are you current on the latest administrative, legislative, and legal developments?

The Internal Revenue Service’s Large Business and International Division (LB&I) has recently turned its focus back to the research tax credit by announcing new campaigns and directives. LB&I’s efforts aim to centralize review and assessment of issues, promote increased compliance, and provide consistency across the nation with respect to examinations.… Read more »

A More Collaborative Tax Controversy Approach?
Strategies for Exam and Appeals

Tax executives are familiar with the scenario: Internal Revenue Service examiners are in the building and are beginning to issue information document requests (IDRs) on routine and sensitive issues. One typical taxpayer response is to go on the defensive. This approach includes not voluntarily identifying issues and transactions; responding to… Read more »

A Tax Executive’s Guide to Spin-offs: 10 Things You Won’t See in Section 355
Advise board and officers to be careful about certain negotiations or public statements during pendency of the spin

Behind the closed doors of a corporate boardroom somewhere in America, the directors of a publicly traded company are discussing the future of their business. For many years, the company has operated two major divisions that have gradually diverged over time. These divisions (having the remarkably original names Business A… Read more »

Data Privacy at a Crossroads
As privacy laws proliferate globally, the IRS expands its ability to seek and obtain taxpayer data

In recent years, two important legal developments have accelerated and are currently on a collision course. The first is the rapid proliferation of data-privacy laws across the globe. As explained below, these laws—such as the European Union’s recently enacted General Data Protection Regulation (GDPR)—broadly prohibit unauthorized collection and transmission of… Read more »

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