Author: Virginia Lorenzo, J.D., LL.M

State Tax Incentives Become Bargaining Chips in a Globally Mobile Economy

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There once was a time when a business’ headquarters location was based on proximity to natural resources and transportation networks. If you owned a mill, you worked near a river. If you exported goods, you were near a port. While some of those geographical limitations still exist, most businesses operating… Read more »

How To Bind Without Getting in One: Avoiding Controversy Over Signature Authority Issues

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Man holding pen in business suit

It’s late in the day. After weeks of review, it’s time to file an entity classification election for an entity in your company’s structure. The election is due today. You have already carefully analyzed the ramifications of the election. Form 8832 has been drafted, reviewed, and approved. All that is… Read more »

The IRS, Privilege, and Transparency
The Experts: Todd Welty, Mark Thomas, and Kevin Spencer

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The IRS has imposed increasing disclosure demands on large, multinational taxpayers, requesting filing of a slew of additional documents and forms. Question: How will the Schaeffler case affect the IRS’ ability to require additional disclosure documents from taxpayers? Answer: In the last decade, the Internal Revenue Service (IRS) has shifted…

TEI Roundtable No. 5: Corporate Structure and the Evolving Tax Function
As the Tax Role Elevates in Importance, So Does Status in Corporate Hierarchy

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Janet Kreliein, Don Rath, and Cooper Monroe

Let’s tell it like it is. The role of the corporate tax practitioner has changed dramatically in the last twenty years as the tax function has expanded in scope and responsibility. Not surprisingly, the status of the head of corporate tax has changed as well, and now more chief tax…

Transfer Pricing: Are We in a Global Tax War?
Expect Controversy To Heat Up in Light of BEPS

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Transfer pricing. This is one of the most complex and controversial areas of corporate tax, occupying considerable time and energy on the part of many of TEI’s members, especially in the last twelve months. What exactly is transfer pricing? According to Mike Patton and Eric Ryan, partners at the law…