2014-Issue 25—Frank Underwood likely would appreciate that as tax advisors, we are often called upon to fight chaos with chaos. Chaos, of course, describing the present state of our tax system. One particularly chaotic area is determining what…

2014-Issue 22—Develop a strategy to successfully manage and settle tax controversies. In light of the impending global war for corporate tax revenue, this article outlines an audit strategy based on the Eight Rules of Air Combat written for fighter…

2014 - Issue 20—For many companies, it happens every three to four years like clockwork — you receive a questionnaire or letter with those infamous words "you have been selected for a sales and use tax audit." Depending on the number of legal…

2014-Issue 18 – It’s a tale as old as time itself: Buyer meets seller. Buyer falls in love with seller’s business. Buyer proposes to seller. Seller accepts buyer’s proposal and transfers assets to the buyer in exchange for consideration,…

2014-Issue 17—In the context of a deal, a buyer of a business that participates in a multiemployer pension plan (MEP) is faced with a series of unique considerations, including balancing the economics of continued participation or withdrawal, as…

2014-Issue 16—In a recent edition of A&M Tax Advisor Weekly, “A Capital Idea — Present and Future Ramifications of the IRS’s Final Repair Regulations,” we provided an overview of the final repair regulations. Given the extensive nature of…

Issue 15-2014 —This edition of Tax Advisor Weekly is a follow-up to an article previously posted, “Entity Simplification: Not So Simple (But Likely Beneficial).” When we published that article, the economic environment was fairly uncertain…

2014 - Issue 14—Last year we discussed an area where taxpayers often leave Section 41 research expenditures on the table: contract research (see Tax Advisor Weekly, “Maximize Your Research Credit With Non-Traditional R&D Groups,” Issue 23,…

2014-Issue 12 — One of the few recent taxpayer-favorable decisions could have a significant impact on more than just homebuilders in similar situations. On February 12, 2014 the Tax court decided Shea Homes Inc. v. Commissioner, 142 T.C.…

2014-Issue 10—Executive compensation continues to be a hot topic for politicians, shareholders, shareholder advisory firms and the media. A major point of contention for these groups revolves around benefits provided to executives in connection with…

2014-Issue 7—Generally, the sale or exchange of an interest in a partnership is treated as the sale or exchange of a capital asset, and therefore resulting gains and losses are capital (IRC Section 741). This is fine if you recognize gains, but not…

2014-Issue 6—It remains hard to say whether the IRS will challenge your transaction by asserting the economic substance doctrine, because the IRS said in December it won’t be issuing anticipated further guidance or an angel list. Therefore, make…

2014-Issue 5—The Internal Revenue Service recently published draft proposed guidance on the competent authority process in the form of Notice 2013-78. This new guidance proposes updates to the set of procedures to be followed by taxpayers seeking…

2014-Issue 3—The Information Document Request (IDR) process that we have all followed in a typical IRS audit in the past has recently undergone some substantial changes that will require an evaluation of your current process for dealing with such…

Issue 2-2014—A common refrain heard through the course of one’s life is that you should always look out for your own best interests, because no one else will. Nowhere is this truer than in the context of acquiring a business. Buyers and sellers will…

2013-Issue 53—The release of the much anticipated final “repair” regulations (Treasury Decision 9636) in September probably stands as the most significant federal tax development of 2013. At over 200 pages in length, the regulations cover a gamut of…

2013 - Issue 52—Along with the holidays, the calendar year-end is quickly approaching, and preparation for the sometimes daunting year-end close will soon be a primary focus. For many in accounting, tax and finance departments, year-end financial…

2013 - Issue 51—It’s the "same as last year" for me, the head of global tax, with the imminent expiration of the Subpart F Look-Through Rule (IRC Section 954(c)(6)). As in past years, this helpful law will likely expire but could then be extended…

2013 - Issue 50—Every year-end brings with it annual rituals and traditions, and even corporate tax departments are not immune. Hence, now is the time to take stock of 2013 and plan for 2014. The year-end planning ritual is becoming more important…

2013-Issue 49—In most organizations, indirect taxes touch multiple business functions, such as purchasing, sales and inventory management. For U.S. sales and use tax and value-added tax (VAT), the consumer ultimately bears the burden of payment of…