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Considerations in Tax Refund Litigation
Is refund litigation the path to releasing “stuck” refunds?

The Internal Revenue Service has seen unprecedented changes this year. Approximately 25,000 IRS employees—or twenty-five percent of its workforce—have accepted the deferred resignation or retired or were laid off.1 When we wrote this article in November, the federal government had been shut down for more than four weeks with only… Read more »

How the IRS May Do More With Less
As the IRS modernizes with AI and other tech, it faces funding cuts and shifting enforcement priorities

Facing ongoing budget constraints and a significant reduction in workforce, the Internal Revenue Service is changing its approach to taxpayer service, enforcement, and collections. Taxpayers and tax practitioners are seeing early signs of how the IRS is leveraging technology and data analytics as well as returning to some old practices… Read more »

The Unconstitutionality of the Brazilian QDMTT
New tax on multinational groups raises legal and equity concerns

On December 30, 2024, the government of Brazil published Law 15,079, which went into effect on January 1, 2025. It instituted the Additional Social Contribution on Net Income (Adicional da Contribuição Social sobre o Lucro Líquido, or ACSLL), a tax that applies to multinational entities operating in Brazil. The ACSLL… Read more »

Sales Tax Traps for Disregarded Entities
A handful of states pose hidden compliance risks

Sales tax rules can be confusing, because states often take different approaches to the same tax concept. In most cases, sales tax obligations apply at the level of each separate legal entity—even if that entity is disregarded for federal or state income tax purposes. Although this rule generally applies in… Read more »

How Does Conformity Impact State Revenues After the OBBBA?
Changes in federal tax law reverberate across state budgets, with conformity choices shaping revenues in vastly different ways

State conformity with the Internal Revenue Code (IRC) refers to how states’ tax codes align with the federal tax code. Most states, for ease of administration and compliance, base their state income tax regimes on the federal IRC, either by using federal taxable income as a starting point or by… Read more »

OBBBA Modifications to US Taxation of International Income
Changes in the new law affect GILTI, foreign tax credits, and inventory sourcing rules, among other international tax provisions

The One Big Beautiful Bill Act (OBBBA), which was signed into law on July 4, has changed US taxation of multinational businesses. The most notable among these changes are various modifications that relate to the former global intangible low-taxed income (GILTI) regime enacted during the first Trump administration as part… Read more »

Are Tax Insurance Proceeds Taxable?
A practical guide for business tax directors on the evolving treatment of recoveries under tax insurance policies

Tax insurance has emerged as a cornerstone of corporate tax risk management. Whether companies use it to protect the outcome of a complex M&A transaction, to backstop the eligibility of a tax credit transfer, or to mitigate the risks of an uncertain deduction, tax insurance plays an increasingly vital role… Read more »

Transfer Pricing in Transition
Mitigating state tax risk while preserving value

Although states experienced significant tax revenue growth during the COVID-19 pandemic, many experienced revenue declines in fiscal year 2024, some for the second consecutive year.1 In response to economic downturns, state governments often intensify audit activity to raise revenue. One major focus for state tax audits has been, and will… Read more »

Managing Canadian Tax Risk
Addressing what your organization may be facing now and in the future

The global tax environment has seen fundamental changes in recent years. Base erosion and profit-sharing (BEPS), the digital economy, and US tax reform have caused changes around the world and, at the same time, fueled the insatiable appetite of governments for more tax dollars. Canada was not sheltered from this… Read more »

US Tariffs: The EU Perspective
Turning tensions into business opportunities

Following his inauguration on January 20, President Donald Trump signaled his intentions regarding trade policy by stating, “I always say ‘tariffs’ is the most beautiful word to me in the dictionary.”1 The Trump administration promptly took action with executive orders, leading to significant tariff measures between, among others, the United… Read more »