2013 - Issue 1—BackgroundThere are many reasons for changes in a taxpayer’s organizational structure. An acquisition or divestiture, for example, can result in considerable changes to the structure of a taxpayer’s organization chart. Changes to a…

2012 - Issue 52—Several of our recent Tax Advisor Weekly articles have addressed the ways in which mature, global, multinational companies may manage their technology and intangible property (IP) in order to operate their businesses…

2012 - Issue 51 — In addition to the accounting method changes that accompany the new tangible property regulations, one of the more significant developments in tax accounting this year is a quiet change in the interpretation of the…

2012 - Issue 50 — Last week’s Tax Advisor Weekly focused on using captive insurance companies to address the growing need for effective risk management strategies, as well as the federal income tax implications of forming a…

2012 - Issue 49 - In this challenging global economy, businesses face increased pressure to control their business risk costs and risk management plans. The risk manager's option to simply "fully insure" via a third-party policy with low…

2012 - Issue 48 - On September 13, 2012, the Treasury Department and the IRS released proposed regulations for corporate equity reduction transactions (CERTs). Almost 23 years after the initial statutory guidance was enacted in 1989 to limit…

2012 - Issue 47 - The Internal Revenue Code is notorious for complicated rules, confusing provisions and differing interpretations of its most simple provisions. For example, the global interest netting provision in Section 6621(d) enacted in…

Even with the election now behind us, great uncertainty remains about what our taxes will look like in 2013 and how looming tax changes will affect companies and their employees. Between talk about the "fiscal cliff" and budget shortfalls, it is…

A company’s tax disclosures reveal critical clues to its underlying health. Buyers and lenders use this information to evaluate the “quality” of a target’s earnings and uncover hidden liabilities, while the IRS uses it to identify overly-aggressive…

Previous issues of Tax Advisor Weekly have highlighted not only the 2009 Union Carbide ("UCC") memorandum decision by the Tax Court, but also the subsequent Second Circuit Court of Appeals hearing in New York City on March 29,…

In Alvarez & Marsal Taxand's recent survey of 302 CFOs, 30 percent said transfer pricing was the area that created the greatest risk for their company. This concern is understandable, as the regulatory landscape governing intercompany…

In the midst of a struggling economy, firms understand the importance of finding and retaining top talent. To recruit and preserve such valuable resources, numerous firms have turned to offering traditional and compensation-related employee loans.…

In what taxable period is an accrual-basis taxpayer allowed a deduction on its federal tax return for state franchise taxes? You'd think the answer to this question would be relatively straightforward compared to other complex tax issues we're…

Much has been written in recent weeks about the $104-million windfall that Bradley Birkenfeld, a former UBS employee, received under the federal Whistleblower Act for divulging to the IRS massive avoidance of federal income taxes by U.S. citizens…

Last year's Nortel Networks decision spurred a spate of optimism and activity surrounding potential sales tax refund opportunities and planning considerations for certain transfers of prewritten software. To the consternation of industry…

As mobile communication devices become more of a necessity than a "nice-to-have" item in the workforce today, a wide array of options, along with new mobile device policies, has emerged. The popular trend has been the "bring your own device" policy…

Every business needs a cost-effective way to manage its compliance requirements while keeping up-to-date on indirect tax developments. For many finance or tax professionals, tax automation can be the key to such support and compliance. When done…

The first step has finally been taken to address an area of tax law that has materially impacted both corporate and individual taxpayers alike for some time. But don't get too excited...it's not what you may think it is. Nevertheless, the passage of…

Preparing and organizing the required documentation for Internal Revenue Service (IRS) examinations is a time-consuming process that has the potential to overwhelm your tax department resources. In order for tax departments to efficiently manage…

In 2011, we published a three-part series called "How Is Your Cloud Taxable?" This series discussed, among other things, how many companies are searching for ways to gain a competitive edge while mitigating costs. IT departments have begun using…