2013-Issue 48—As 2013 comes to an end and our thoughts turn to the holidays, here are a few compensation planning opportunities that should be considered.1.      2013 Bonus DeductionsMany companies plan to pay 2013…

2013 - Issue 46—Everyone loves a good deal, and the only thing better than a good deal is a great deal. Since the enactment of the federal income tax in 1913, certain taxpayers have looked for ways to structure their affairs to get a great deal for…

2013 - Issue 45—If you are a taxpayer who has excluded certain activities that you deemed to be mere “packaging” or “assembly” from your Section 199 Domestic Production Activities Deduction (DPAD), now is the time to reassess those activities. A…

2013-Issue 44—Did you know that Treasury and IRS officials appear close to issuing newly proposed Treasury regulations that could significantly impact the way partnership debt is characterized and allocated? The Tax Court’s decision in Canal…

2013-Issue 43—As the end of 2013 tiptoes closer, many California taxpayers may soon be impacted by new replacement incentives enacted in July (AB 93 and SB 90). The old California enterprise zone program ceases to exist at the end of 2013, and…

2013 - Issue 42—As we approach the year-end for most companies, we find that once again, the R&D tax credit is set to expire on December 31. As Congress grapples with the aftermath of the government shutdown, the latest round of federal…

2013-Issue 41—Recent headlines addressing transfer pricing (Starbucks, Google, Apple) have prompted global tax authorities and regulators to be on high alert regarding intercompany transactions. Transfer pricing remains an easy target for tax…

2013-Issue 40—This edition of Tax Advisor Weekly updates our previous discussion on intercompany debt and outlines recent case law developments in this important area of tax law.Two months ago, we discussed the practical considerations…

2013-Issue 39—Companies that have installed “bolt-on” sales and use tax solutions with the goal of automating their transactional tax compliance function need to consider this question: Is the solution performing at the anticipated optimum level?…

2013 - Issue 38—On September 5, 2013, the IRS issued proposed regulations that are intended to clarify what most taxpayers already understood to be correct for the past 60 years. In particular, the proposed regulations, if adopted, make abundantly…

Given the recent economic downturn, lingering losses still plague the balance sheets of many companies holding debt. As if an anemic economic recovery were not enough, these companies must contend with uncertain tax rules that can produce different…

2013-Issue 36—Overview of FATCACongress enacted the Foreign Account Tax Compliance Act (FATCA) in March 2010 in an attempt to discourage offshore tax evasion. Specifically, FATCA tries to make it easier for the Internal Revenue Service and the…

Issue 35-2013 — If you are acquiring assets, make sure you really believe — and are willing to live with — the purchase price allocation agreed to and reflected in your purchase agreement. In other words, if you think you can do a more detailed…

2013-Issue 34—As the economy continues to heat up and businesses are putting into play long-held cash, entities that acquire corporations with significant net operating losses (NOLs) need to be aware of the interplay between Internal Revenue Code…

2013-Issue 32—You are the U.S. tax director of a global multinational's U.S. subsidiary. One day you get a call from the global CFO at the foreign parent, who tells you they want to issue intercompany debt to the tune of $500 million. As you run a…

2013-Issue 30—On April 1, 2013, the Internal Revenue Service issued proposed regulations providing guidance on the $500,000 deduction limitation for compensation paid by covered health insurance providers (CHIPs) to employees. Don't think you're a…

2013-Issue 29—New York's statutory resident rules have long been a source of contention between nonresident taxpayers and the Department of Taxation and Finance. A case decided late last year, In the Matter of John Gaied v. New York State Tax…

2013-Issue 28—On August 27, 2012, in Historic Boardwalk Hall LLC v. Comm'r, 694 F.3d 425 (2012), the United States Court of Appeals for the Third Circuit sided with the IRS and denied historic rehabilitation credits for a state authority's…

2013-Issue 27—As the economy continues to improve and companies are investing long-held cash in domestic expansion programs, it seems appropriate to revisit state enterprise zones and the benefit they can bring to a business. Many states have…

2013-Issue 25—The Affordable Care Act, which became law in 2010, radically changes how U.S. companies will provide healthcare benefits to employees. The Act is designed to phase in changes over time, with many of the major changes, including the…