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, 2012.

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. Whether such loans are constructed for retention or to administer employee aid, their tax treatment should be closely considered.

Do you know how your subsidiaries are winning contracts in the most corrupt countries in the world?

A&M recently spoke with the Head of the UK Tax Authority Transfer Pricing Team regarding key issues impacting business

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 the Mobile Workforce State Income Tax Simplification Act of 2012 by the U.S. House of Representatives in May is an attempt by Congress to substantially simplify state income tax law by imposing a uniform standard for nonresident taxation and employer withholding.

It is widely held that the reality of a transaction should ultimately govern when interpreting the meaning of a contractual arrangement. The "substance over form" doctrine, which originated under the Supreme Court's ruling in Gregory v. Helvering, is frequently invoked by tax authorities to frame the interpretation of a contractual arrangement whose meaning is called into question.

"Give someone an inch and they'll take a mile." Although this phrase is usually not associated with state taxation, perhaps it should be. More specifically, in the absence of guidance from the United States Supreme Court, states have sometimes taken the inch they have been given in determining what activities are sufficient to constitute nexus for income tax purposes and stretched this inch into a mile.