On September 8th, Treasury and the IRS released Notice 2023-63 (the Notice), which showcased the rules they intend to propose regarding the mandatory requirement to capitalize and amortize specified research or experimental (SRE) costs under section…

The transition to capitalizing research and experimental costs under section 174 has been fraught with increasingly complex issues without much-needed guidance to resolve them. With the 2022 tax filing season well underway, companies are taking…

Many investors who are aware that a new tax applies to stock buybacks by public corporations (including the purchase of stock of a public corporation by its controlled affiliate) may not be aware of the full scope of the tax as enacted by Congress…

On March 31, 2023, FedEx, by virtue of a favorable court ruling on its challenge of Treasury regulations, delivered a same-day gift to many U.S.-based multinationals. In FedEx Corp. v. United States, the U.S. District Court for the Western District…

In My Cousin Vinny, Mona Lisa Vito (played by Marisa Tomei) asked Attorney Vinny Gambini (played by Joe Pesci): “Didn’t they teach you [procedure] in law school?” In response, Gambini replied: “No. That's not what they teach you. They teach you…

On March 15, 2023, the Financial Accounting Standards Board (FASB) published a proposed Accounting Standards Update (ASU), “Income Taxes (Topic 740): Improvements to Income Tax Disclosures,” aimed at providing greater transparency into entities’…

On March 9th, the Biden Administration submitted its fiscal year 2024 budget recommendation to Congress, primarily recycling or tweaking previously defeated proposals to increase taxes on corporations and wealthy individuals and ensure large…

The one thing distressed companies need, in or out of bankruptcy, is cash, and unfortunately for them, the new corporate alternative minimum tax (CAMT), which is effective this year, could wreak havoc on their tax planning. While the IRS released…

Just five days before the new year, Treasury and the IRS revealed their intentions to issue regulations that will govern how taxpayers should apply two new corporate tax provisions enacted by the Inflation Reduction Act (IRA) that are effective…

We recently attended the Institute for Professionals in Taxation’s (IPT) 2022 Annual Sales Tax Symposium, where experts in the field presented on the hot trends and important matters in sales and use tax. Numerous topics were discussed, including…

For decades now, we have been advising clients that the 1979 tax treaty between the U.S. and Hungary (the U.S.-H Treaty) is about to be replaced, any day now, with a new treaty. Then suddenly, on July 8th, the U.S. Treasury Department gave notice…

While waiting for the proverbial ink to dry on the Senate’s vote on the bill to boost the U.S.’s competitiveness with China, Senator Joe Manchin, in what many perceive to be a master manipulation, announced that he struck a deal with Senator…

Multinational companies operating in Brazil must evaluate their current transfer pricing models to determine how they will adapt to the new transfer pricing system proposed by the Brazilian tax authority, which is consistent with the arm’s length…

On April 4th, the United States District Court for the District of Colorado in Liberty Global Inc. v. United States invalidated a U.S. Treasury Department regulation which attempted to backfill certain aspects of the section 245A dividends received…

On Monday, March 28th, the Biden Administration transmitted its fiscal year 2023 budget recommendations to Congress, which lay out the Administration’s discretionary spending plan for the fiscal year beginning October 1, 2022, along with its long-…

Article featured on Thomson Reuters’ Taxnet Pro, February 2022.  On February 4th, the OECD released a public consultation document entitled “Pillar One – Amount A: Draft Model Rules for Nexus and Revenue Sourcing” (the Initial Amount A Rules…

Revamped teleworking arrangements that have become the “new normal” following the COVID-19 temporary shelter-in-place paradigm could trigger new state income, sales and use, or employer withholding tax obligations that some businesses may have…

First quarter estimated tax payments and income tax provisions might not be top of mind just yet, but they should be with myriad changes that could require new computations, processes, and systems, and affect financial results and cash flow…

As the fate of the Build Back Better Act (BBBA) is in limbo with Senator Joe Manchin’s declaration that he would vote no on the bill in its current form, global efforts continue toward implementation of a two-pillar international tax system (…

New tax reporting requirements for cryptocurrency transactions established by the Infrastructure Investment and Jobs Act (IIJA), enacted into law on November 15th, are causing angst in the crypto community. The questions and concerns stem in part…