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Intercompany Transactions: Current State Tax Developments
Nexus and documentation are key issues in understanding the current intercompany transaction legal landscape
Intercompany transactions can be used to shift income from entities with a physical nexus in many states to a related member with a limited nexus in favorable taxing jurisdictions. In moving to combat the benefits received from such intercompany transactions, states tend to employ one or more of the following… Read more »
LB&I Audits: Old Lessons, New Approach
Transparency, Collaboration, Fair and Efficient Resolution: No Argument with Goals, but the Devil Is in the Implementation Details
Those who ignore history are doomed to repeat it. That adage is true in all walks of life, but it is particularly appropriate as the IRS prepares to implement its most recent initiative for examinations by the Large Business & International division (LB&I), as described in the draft release of… Read more »
AI in the Tax Department: Getting Tax a Seat at the Table Artificial intelligence (AI) is reshaping business functions rapidly, yet many…
Planning for IRS Audits in an Era of Uncertainty In its ongoing crusade against so-called “basis-shifting” transactions, the Internal…
Transfer Pricing and Valuation in Financial Transactions Business transactions such as mergers, acquisitions, and reorganizations often necessitate…
Andreia Verissimo Andreia Verissimo, the senior manager for US tax policy at…
TEI Roundtable No. 52: FASB Accounting Standards Update 2023-09—Income Taxes (Topic 740) As financial reporting evolves, the Financial Accounting Standards Board (FASB)…
TEI Roundtable No. 53: Using AI for Tax Law Research As artificial intelligence continues its scorching rise, in-house tax professionals…