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Sauce for the Goose: Standards Applicable to Taxpayers, Practitioners — and the IRS
The contention among the parties results not from a lack of reasonable standards, but rather from an apparent failure by some IRS personnel to follow those standards in practice and the relative lack of accountability.
The relationship between the Internal Revenue Service’s Large Business & International (LB&I) Division and its constituent taxpayers is complex, marked by alternating episodes of cooperation and contention. LB&I often invites taxpayers and their representative groups to participate in the agency’s critical self-evaluation and listens closely to suggestions and complaints. At… Read more »
Trends and Developments in Canadian Tax Controversy and Jurisprudence
Transfer pricing issues, increases in voluntary disclosures, and procedural disputes are among major developments, but what will happen in 2016 — and beyond?
The Canada Revenue Agency (CRA) continues to employ a risk-based approach when auditing large corporate taxpayers, focusing on high-risk areas such as aggressive tax avoidance and international tax planning. Information-gathering involves the use of written requests and requirement letters to routinely attempt to compel delivery of taxpayer information. However, the… Read more »
Canadian Sales Tax Reform
How the U.S. Neighbor to the North Transitioned From a Multistage Sales Tax to an Almost Fully Harmonized Single VAT — in Just One Century
The problem with good tax policy is that politics always gets in the way. And for the United States—a country whose sales tax system (at least from a nonresident’s perspective) cries out for reform—your neighbor to the north and our experience may offer a cautionary tale of inspiration. After all,… Read more »
TEI Roundtable No. 9: Six Past TEI Presidents From Canada Share Their Stories
Spanning Four Decades, There’s a Lot to Learn From These Former Head Honchos
In this special issue focused on Canada, it seemed only appropriate that the Roundtable we convened also reflect a Canadian bent. To that end, we invited the six living TEI presidents from Canada to discuss their tenures at the helm of the organization, including Vincent Alicandri (2008–09), David Burn (1986–87),… Read more »
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 »
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…
TEI Roundtable No. 53: Using AI for Tax Law Research As artificial intelligence continues its scorching rise, in-house tax professionals…
TEI Roundtable No. 52: FASB Accounting Standards Update 2023-09—Income Taxes (Topic 740) As financial reporting evolves, the Financial Accounting Standards Board (FASB)…
Andreia Verissimo Andreia Verissimo, the senior manager for US tax policy at…