Buyers and sellers of real property typically expect some tax consequences from the transaction. However, they generally focus on federal tax issues, in particular issues that may impact their federal income taxes. But most states also impose…

With the continued volatility of today’s business and economic environment, hedging strategies designed to deal with these uncertainties remain a smart business move. With fuel and raw material prices fluctuating widely over the past few years and…

Regulatory UpdateIn October 2010, we made reference to Section 989G(b) of the Dodd-Frank Act. This section required the SEC to conduct a study to determine how the commission could reduce the burden of complying with Section 404(b) of the Sarbanes-…

In the typical corporate or private equity transaction, both the buyer and seller incur significant service provider costs, often in the millions or tens of millions of dollars, in connection with the closing of a transaction. In most cases, a…

Congress recognized that incorrect basis reporting for capital gains cost the government an estimated $6 billion to $9 billion per year in lost tax revenue. To help close the "tax gap," Congress recently implemented new cost basis reporting rules…

The actor Gregory Peck said, “Tough times don’t last, tough people do, remember?” Although this quote is generally directed towards individuals, it is equally applicable to states that are attempting to “get tough” to make it through these difficult…

Wall Street reform and related financial regulation designed to prevent the U.S. taxpayer from having to “bail out” another financial crisis is now a reality. The Federal Deposit Insurance Corporation (FDIC) recently issued proposed regulations…

Recent trends in state and local income tax rules have led to increasing questions about how to treat them under Financial Accounting Standard (FAS) 109 and Financial Accounting Standards Board Interpretation (FIN) 48. This article explores some of…

I don’t often use the word “wow” in the title of an article in these newsletters. The last time I did was in January 2010 when the IRS Commissioner announced in a speech to the New York State Bar Association that certain corporate taxpayers will be…

Our Concerns About the New DOL Position The Department of Labor has launched an aggressive program to determine whether companies are complying with the Form 5500 and associated audit report requirements in a timely way. The DOL is authorized to…

Partnership income allocation complexities are on the rise across the board. The aggregation rules are broken but should they be fixed or scrapped? Is there a practical solution? Over the past 15 years or so, partnerships have struggled with making…

As companies continue to look for ways to minimize IT infrastructure costs and gain the benefits of increasing technological advantages, Software as a Service (SaaS), or cloud computing, will continue to grow. Most states impose sales tax on the…

Now that tax season is behind us and we have had a chance to catch our breath, the time has come to brush up on the constantly changing landscape of FBAR reporting.Over the past couple of years, the IRS and the Justice Department have been…

In the current economic environment, many transfer pricing optimization strategies have come under heavy attack from both tax authorities and the general public. Strategies such as the migration of intangible property have historically been popular…

The world of value-added tax is a rapidly changing environment. The European Union recently overhauled its VAT system, made even more complicated by myriad austerity programs that have sent rates climbing. In Asia, India is set to announce changes…

As U.S.-based multinational corporations continue to expand global operations, supply chain initiatives are driving production and management functions increasingly to relatively low-cost jurisdictions. India remains among the commonly considered…

The research credit continues to be an area of intense scrutiny during IRS examinations despite strong support from the President and Congress. ccFor tax departments to efficiently prepare research tax credit calculations and supporting materials,…

As the IRS issues additional guidance on the Foreign Account Tax Compliance Act (FATCA) in Notice 2011-34, just over a year from the day the legislation was first passed, the U.S. government continues its mission to identify U.S. persons with…

A Google search for “corporate accountability” nets 534,000 hits (with this writing, make that 534,001). Heavy interest in the topic is unsurprising, given the numerous corporate upheavals, scandals and the like over the past few years. In a…

In theory, the relationship between Congress, the Internal Revenue Service and corporate taxpayers is relatively simple. Congress enacts tax legislation, corporate taxpayers apply the Internal Revenue Code to their operations, and the IRS enforces…