2015-Issue 27—In the years since the economic downturn, many U.S.-based multinational companies have been utilizing their large net operating losses to fully offset taxable income. However, as these companies utilize their NOLs and return to their…

2015-Issue 26—These weekly commentaries typically deal with corporate and for-profit business issues, but this week we are changing it up and showing some love to the tax-exempt community. Specifically, we discuss the mechanism by which tax-exempt…

2015-Issue 25—State legislatures are working hard to make changes to their tax systems in an attempt to stay competitive with their neighboring states and broaden their tax base. As state legislative sessions adjourn, we see a trend of numerous…

2015-Issue 24—A recent decision by the Delaware Court of Chancery should cause many employers to at least consider amending incentive plans that cover their directors and to review their peer groups. The basis of the court’s holding in Calma v…

2015-Issue 24—A recent decision by the Delaware Court of Chancery should cause many employers to at least consider amending incentive plans that cover their directors and to review their peer groups. The basis of the court’s holding in Calma v…

2015-Issue 23 – Whose refund is it? What happens if the parent of a consolidated group receives a refund that came about from the use of a subsidiary’s loss — must it be paid to the subsidiary? When the group is one big happy family,…

2015-Issue 22—All of this has happened before, and this will all happen again. The scenario plays out universally: buyer meets target; buyer immediately falls in love with target; buyer and target are about to tie the knot, but as the courting…

2015-Issue 21—A common structure for U.S.-based multinationals entails the use of holding companies in certain jurisdictions such as Ireland, the Netherlands, Switzerland or Luxembourg. A properly structured holding company along with an affirmative…

2015-Issue 20 — In the years since Section 409A of the Internal Revenue Code was first implemented, most practitioners have become comfortable with the idea that a document failure may be remedied outside the formal IRS correction programs without…

2015-Issue 19—The subject of master limited partnerships (MLPs) has made its way back into the tax headlines recently because of the Treasury and IRS’s issuance of proposed regulations in early May 2015 (see Federal Register, Vol. 80, No. 87 or 26…

2015-Issue 18—In case you have missed the financial headlines, there is an ongoing heavyweight bout in the federal tax controversy arena that we should all be watching with interest. It may not have the aura of the recent Floyd Mayweather Jr. versus…

2015-Issue 17—The Financial Accounting Standards Board (FASB or Board) has embarked on a simplification initiative to identify, evaluate and improve areas of GAAP for which the cost and complexity can be reduced while maintaining or improving the…

2015-Issue 16—Many IRS compliance forms ask for a taxpayer to disclose the fair market value and adjusted basis of certain assets, specifically in the international tax compliance arena. This is a continuing trend with respect to reporting and…

2015-Issue 15— Everyone loves good surprises. Examples of good surprises include the following (not an all-encompassing list): surprise puppies, surprise gold, surprise unicorns, etc. However, the same cannot be said for bad surprises. No one likes…

2015-Issue 14—The Financial Accounting Standards Board (FASB) is working on a project to simplify accounting and tax accounting for stock-based compensation under Accounting Standards Codification (ASC) Topic 718 (formerly known as FAS 123(R)).…

2015-Issue 13—As companies continue to grapple with how to grow revenues, reduce costs and remain competitive in today’s global economy, corporate tax departments frequently find themselves under increased pressure to manage their effective tax rate…

2015-Issue 12—There are a number of reasons why a company might consider moving its corporate headquarters, relocating key operations or outsourcing certain aspects of its business. Once the decision has been made to execute such a material…

2015-Issue 11—The U.S. economy is constantly fluctuating, which makes for an ever-changing landscape in corporate America. For many companies, uncertainty in the economy can result in an array of changes such as downsizing, mergers, acquisitions and…

2015-Issue 10—Often, Subchapter K, the codification of partnership taxation, can involve deemed transactions that raise the specter of gain recognition under a number of anti-deferral provisions or simultaneous transactions where an ordering of…

2015-Issue 7—Reimbursing and substantiating business travel expenses can be cumbersome and time-consuming. It usually involves employees collecting receipts as they travel and maintaining records that note the time, place and business purpose of…