Features
Market Sourcing or Bust: The Kitchen Sink Approach of COP-Sourcing States
The binary nature of the determination makes COP sourcing controversial
The division of multistate business income among the states is accomplished through formulary apportionment. State formulary apportionment provisions increasingly rely on the receipts factor to divide income, sharpening the focus on the sourcing of receipts. Although many states have transitioned to a market-sourcing (also known as destination sourcing) approach, historically… Read more »
TEI Roundtable No. 42: A Deep Dive Into the Murky Waters of UTPs
Uncertain tax positions (UTPs) offer taxpayers both opportunities and challenges. We wanted to take a closer look at this important issue, so, of course, we assembled a roundtable of knowledgeable tax professionals, including George Clarke, partner at the Washington, D.C., office of Baker McKenzie; George Hani, member with Miller &… Read more »
How Remote Workforce Programs Trigger Myriad Tax Problems—Part Two
Analyzing taxable presence and nexus issues for employers
The coronavirus pandemic created an explosion in remote workforce programs, some temporary but others indefinite or permanent. Remote work situations can arise in a wide range of settings—some are planned, and others arise well after the fact as a surprise to the in-house tax team. One critical tax issue introduced… Read more »
GloBE Meets GILTI—Part Two
What’s the status of implementation?
Our article, “GloBE Meets GILTI,” which appeared in the January/February issue of Tax Executive, addressed how taxes on global intangible low-taxed income (GILTI) might be allocated. Sadly, the story was already out of date by publication. This follow-up article addresses not the possibilities, but rather what the Organisation for Economic… Read more »
TEI Diversity, Equity, & Inclusion Survey Results
Uncovering root challenges in recruiting and retaining talent
The many benefits of a diverse and inclusive workplace include increased revenue, improved employee engagement, and more innovation. Despite the great strides that have been made in driving awareness of the importance of diversity, equity, and inclusion (DEI) in the workplace, much work still needs to be done within the… Read more »
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 »
Embracing ESG: Four Ways Tax Departments Can Add Value
Leaving tax departments out of the discussion is unfortunate—and often costly
Environmental, social, and governance (ESG) considerations command a continually growing share of attention in organizations of all types as various stakeholder groups sharpen their focus on sustainability, equity, and accountability. Today more and more investors, consumers, and employees make decisions based on an organization’s ESG strategy, policies, and actions. As… 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 »
An Overview of the EU Public Country-by-Country Reporting Rules The European Union (EU) has long been at the forefront…
Optimizing Tax Through Structured Data Storage and Data Pipelines In today’s fast-paced digital business environment, tax departments are under…
Preparing Now for 2025 Tax Legislative Activity Editor's note: This article was finalized prior to President Donald…
TEI Roundtable No. 51: The Future Corporate Tax Department As tax moves into the future, in-house professionals are experiencing…
How Tax Insurance Can Be a Valuable Tool for Managing Transfer Pricing Risk in 2025 and Beyond Heightened regulatory scrutiny around the world has made transfer pricing…
TEI to Comment on New Proposed Section 987 Regulations The US Treasury Department and Internal Revenue Service published new…