Features
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 »
TEI Roundtable No. 29: The Evolving Dynamic in IRS Appeals
There’s a blurring of the lines between Exam and Appeals
Every TEI member knows that a critical part of tax administration is the Internal Revenue Service’s Appeals process. But how has it changed in the last decade? To examine this issue, we convened an outstanding panel of corporate tax practitioners in this space, including Jean Pawlow, partner in the tax… Read more »
TEI Roundtable No. 28: The Landmark Tax Legislation’s Impact on International Tax
A 2020 perspective
It’s been a couple of tax cycles since the most comprehensive legislative revisions to the tax code in more than three decades were enacted. To take a look back, focus on the present, and take a quick look at the future concerning its impact on international tax issues, we convened… Read more »
OECD Races Toward Completing Final Report on Digital Economy
But two fundamental “pillars” present structural challenges
The Organisation for Economic Co-operation and Development (OECD) is racing toward meeting an ambitious target by the end of the year that could radically change the way all multinational enterprises (MNEs) are taxed. The target—a final report—was set forth in January 2019 under the cover of addressing the digital economy.1… Read more »
Unilateral Taxation of the Digital Economy
The fight is not over yet—it’s only beginning
Notwithstanding the recent efforts of the G20/OECD Inclusive Framework on BEPS (hereafter the IF) to develop a uniform, multilateral, and consensus-based solution for taxing the digital economy, legislatures and tax administrations around the world continue to propose and enact a host of largely uncoordinated digital services taxes (DSTs) and other… Read more »
Diving In: Platform Transactions and the OECD Digital Economy Effort
How the Model Rules address tax considerations related to the gig and sharing economy
Although much of the tax world has been focused on the Organisation for Economic Co-operation and Development’s two-pillar framework for addressing the tax challenges arising from the digitalization of the economy, a separate OECD effort with a potentially even broader reach is well underway. On February 19, 2020, the OECD… Read more »
Deftly Navigating an MTC Audit: Considerations for Taxpayers
Check out this stat: In the last three years, the MTC Audit Program has recommended state tax assessments in excess of $45 million annually
As recently recognized by Tax Analysts, the Multistate Tax Commission (MTC) has been gaining in prominence and, arguably, effectiveness.1 One of the MTC’s several activities is to administer audits on behalf of states. The MTC’s Joint Audit Program (Audit Program) is authorized by the Multistate Tax Compact and was initiated… Read more »
TEI Tax Technology Seminar Set to Deliver Once Again Each year, TEI’s Tax Technology Seminar brings together in-house tax…
Sales Tax Traps for Disregarded Entities Sales tax rules can be confusing, because states often take…
Overreliance on AI for Tax Advice: A Cautionary Perspective With the increasing popularity of artificial intelligence (AI), many people…
How Is Tax Policy Shaping the Future of Clean Energy Investment? US electricity demand is accelerating at a pace few anticipated.…
Considerations in Tax Refund Litigation The Internal Revenue Service has seen unprecedented changes this year.…
The Unconstitutionality of the Brazilian QDMTT On December 30, 2024, the government of Brazil published Law…