Features
States Fine-Tune Market-Based Sourcing Rules Through Regulation
The devil is in the details in this complex, emerging issue
In 2015, the rubber met the road, and states began to accelerate the adoption of detailed regulations to accompany what is often vague statutory language to source receipts from the sale of services and intangibles based on the location of the “market.” In this article, we survey the key proposed… Read more »
Deploying Company Foundations in Battle for Tech Talent
Managing compliance issues, planning opportunities for tax departments are key concerns
With top companies in Silicon Valley and elsewhere engaged in heated competition to fill the increasing number of open job positions requiring technical skills, initiatives to expand the country’s pipeline of science, engineering, and technology talent is becoming a renewed priority for corporate philanthropy. Corporate tax departments have an important… Read more »
TEI Roundtable No. 8: Tax Talent in Transition
How to plan your next steps in the face of M&As, spinoffs, bankruptcies, outsourcing, and changing demographics
The days when a young tax professional at a corporation worked his or her way up the ladder and stayed with the same company for an entire career are falling by the wayside. True, those days are not disappearing entirely, but most tax professionals move among several different opportunities at… Read more »
TEI Roundtable No. 7: Engaging Emerging Tax Professionals
Tax Executives Institute has implemented several initiatives aimed at increasing participation among emerging tax professionals, including the formation of an Emerging Tax Professionals Subcommittee. Tax Executive convened a roundtable discussion, moderated by Senior Editor Michael Levin-Epstein, to find out what the subcommittee was doing and the ways emerging tax professionals… Read more »
The New LB&I
Recent IRS reorganization raises panoply of significant issues
For a large majority of business taxpayers and their in-house tax professionals worldwide, the Large Business & International Division (LB&I) of the Internal Revenue Service (IRS) represents the principal point of regular interface with the U.S. taxing agency. Thus, any changes, whether large or small, in scope, focus, or operation… Read more »
Altera Deconstructed: A Nuanced Alteration in Tax Law
Tax Court’s Unanimous Opinion Deals With Unusual Regulatory Situation
On July 27, the Tax Court issued a unanimous opinion1 in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), in which the court held that Treas. Reg. § 1.482-7(d)(2) is invalid. It is relatively rare for a court to invalidate Treasury regulations, and, for that reason alone, the decision… Read more »
Are You Considering an Advance Pricing Agreement?
Companies Need To Conduct Benefit Analysis To Determine If APA Is Best Approach
In 1991 the Internal Revenue Service (IRS) established the Advance Pricing Agreement (APA) program, allowing a taxpayer to request that the IRS, and potentially other countries, prospectively approve its transfer pricing facts, transfer pricing methodology, and arm’s-length range of results. The certainty provided by this prospective approach, combined with the… Read more »
The OECD’s BEPS Final Report
Part I: Introduction and Background 15 Actions, Dozens of Questions Maybe the anticipation didn’t reach that of ardent fans waiting for the trailer to the next Star Wars movie. And maybe it didn’t rival that of passionate followers of Harry Potter breathlessly lining up at midnight to make sure they… Read more »
The Trials and Tribulations of the Family Office
Get ready to deal with the trappings of wealth and leveraging the next generation’s tax exemptions
If you’re a veteran family office adviser, you’ve spent decades working with the family’s estate-planning counsel to ensure that wealth is passed to succeeding generations as tax efficiently as possible. You faithfully oversee the implementation of annual exclusion gifts, intrafamily loans, and rolling grantor-retained annuity trust (GRAT) programs, and you… Read more »
Roundtable No. 6 The Evolving Role of the Chief Financial Officer
As Compliance, Reporting, and BEPS Become More Complicated, so Does the Role of the CFO
Channeling Kevin Bacon in the movie A Few Good Men, these are the facts, and they are indisputable: As the role of the chief tax officer (CTO) becomes geometrically more complex (see Roundtable No. 5, September/October 2015 issue of Tax Executive), so does that of the chief financial officer (CFO).… Read more »
AI in the Tax Department: Getting Tax a Seat at the Table Artificial intelligence (AI) is reshaping business functions rapidly, yet many…
TEI Roundtable No. 51: The Future Corporate Tax Department As tax moves into the future, in-house professionals are experiencing…
The Impact of AI in R&D Tax Credits For the last several years we’ve heard that artificial intelligence…
Making Sense of CAMT Complexity The corporate alternative minimum tax (CAMT) under Section 55 of…
Question: What Are the Key Updates in the FASB Income Tax Disclosure Requirements? In 2023, the Financial Accounting Standards Board (FASB) issued Accounting Standards…
Breaking Down Real-Time Controls in Global Tax As governments implement digital approaches to tax filing, reporting, operations,…