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State Aid: What It Is, and How It May Affect Multinationals and Tax Departments
European Commission’s actions against member states bear close scrutiny

Never before has international taxation been in such a spotlight in the business press. Cross-border mergers, international tax policy, and base erosion and profit shifting (BEPS) have each been the subject of major front-page articles in the financial news. Over the last two years another topic has increasingly been in… Read more »

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 »

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 »

How To Bind Without Getting in One: Avoiding Controversy Over Signature Authority Issues

It’s late in the day. After weeks of review, it’s time to file an entity classification election for an entity in your company’s structure. The election is due today. You have already carefully analyzed the ramifications of the election. Form 8832 has been drafted, reviewed, and approved. All that is… Read more »

The Impact of Loving and Ridgely on Corporate Tax Practice
Former OPR Director Reflects on Her Tenure at the IRS

Many TEI members are acquainted with the IRS’s Office of Professional Responsibility (OPR) and Karen Hawkins, its director until just a few months ago. In the first day of her new life, Hawkins graciously agreed to talk to Tax Executive about her tenure at OPR and the impact of two… Read more »

Forging Forward — But How Fast and in Which Direction?
Data rules the tax technology roost, elevating professionals who embrace its potential, but the “new normal” is not without its pitfalls

In the world of real estate, it’s all about location, location, and location. In the tax world, it is becoming all about data, data, and data. And whatever facet of tax technology you’re talking about—whether it’s hardware, software, Big Data, the cloud, data storage, or cybersecurity—the data are the key drivers.… Read more »

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 »

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