Federal
Buying and Selling CFCs Under New Corporate Alternative Minimum Tax Regime
Statute may prove expensive and cumbersome
As part of the Inflation Reduction Act, Congress enacted a new corporate alternative minimum tax (CAMT) that may prove both expensive and cumbersome for large multinationals. Added to the insult of the minimum tax that must be paid is the injury of a rude awakening: that tax professionals can no… 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 »
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 »
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 »
Tips From The Art of War to Help in Your Research Credit Battle
Some may consider the IRS a nemesis, but your battle may be gathering the necessary data and documentation to calculate and support the credit
The legendary ancient Chinese general Sun Tzu has influenced Eastern and Western military thinking, coaching strategy, and now research tax credits.1 Some may consider the Internal Revenue Service a nemesis, but perhaps your own battle is to gather the necessary data or documentation to calculate and support the credit. To… Read more »
Much Ado, but Little New: A Guide to Section 951(a) After Build Back Better
What are the ramifications of Congress’ proposal?
The definition of “pro rata share” in Section 951(a)(2) is fundamental to the subpart F regime. That regime, of course, dates to the John F. Kennedy administration.1 Most words in current Section 951(a)(2) do, too. Though Congress amended Section 951(a)(1) on numerous occasions, it has left undisturbed the words of… Read more »
TEI Roundtable No. 37: Lessons Learned From TCJA Implementation
What are the implications for Biden’s proposals?
This roundtable was conducted on October 27 as the closing plenary session of TEI’s 76th Annual Conference in Florida. The session, Lessons Learned From TCJA Implementation and Implications for Biden’s Proposals, featured four distinguished panelists who shared their perspectives on the practical implementation and administration of business tax reform legislation:… Read more »
Government Aid Disclosure—Spotlight on the CARES Act
What accounting rules and guidance did companies follow to report receipt of government aid?
The United States has spent more government aid to combat the COVID-19 pandemic than at any other time in the country’s history. Due largely to pandemic spending, the United States federal government debt increased from $22.7 trillion to $28.5 trillion in the past two years, with much of the increased… Read more »
Who Is Interested in My Request for Interest?
Procedural missteps can risk taxpayers’ pursuit of overpayment interest from the IRS
The law is clear: “If a taxpayer overpays its taxes, the IRS owes the taxpayer interest on that amount.”1 This obligation certainly characterized the Internal Revenue Service’s 2020 fiscal year, in which the IRS paid more than $3 billion of overpayment interest to taxpayers.2 This figure is just the latest… Read more »
Let’s Make a Federal Case Out of It: Time to Revisit the Tax Injunction Act
There’s been no change in the TIA in more than 80 years—really
Most state taxpayers would prefer to litigate state and local tax cases in federal courts. However, disputes over state and local taxes are almost always decided by state courts. Although litigation in state court may seem natural and obvious to most state tax professionals, it is somewhat odd given the… Read more »
Tax’s Role in Tech Transformation As tax experiences its own transformation with technology, companies are…
Key Challenges and Opportunities for Tax Directors in a Tightening Economy Navigating a tightening economic cycle—characterized by prolonged high interest rates…
State and Local Tax Implications for a Remote Workforce State and local tax issues related to remote workforces have…
TEI Roundtable No. 48: AI Implementation in Today’s Tax Landscape As artificial intelligence (AI) gains traction throughout the business world,…
Passing the Torch, TEI Proud It’s amazing how quickly a year, this past year, has…
Meeting Pillar Two Calls for Tax Transformation and Single-Solution Efficiencies A wait-and-see attitude characterizes this year’s global tax landscape, with…