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Thought Leadership

Maximizing the Opportunity of Transfer Pricing Design through Centralized Procurement

May 11, 2011
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 for large multinational corporations, but they are now being scrutinized heavily and can often result in disagreements between taxpayers and tax authorities (disagreements that have been well publicized).
Thought Leadership

Working as an In-House Tax Team on Transfer Pricing

April 26, 2011
In an economic environment that has dramatically changed over the past few years, transfer pricing is gaining more and more importance not just as a necessary evil (i.e., compliance with local legislation), but also as a planning tool to optimise a group’s tax effectiveness, thereby improving shareholder return.
Thought Leadership

Unforgiven: Lack of Proper Documentation Can Jeopardize Your Research Credit

April 21, 2011
The research credit continues to be an area of intense scrutiny during IRS examinations despite strong support from the President and Congress. One of the most common reasons for IRS disallowance of reported research credits is lack of substantiation, but preparing and organizing required research credit documentation is a time-consuming activity that can potentially overwhelm your tax department resources.
Thought Leadership

Covering Your Assets: Mitigating Officer Liability for Unpaid State Taxes

April 6, 2011
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 business climate of budget cuts, employee layoffs and widespread reporting of corporate losses, corporate officers have become lightning rods for criticism, with many commentators demanding that executives be held accountable for their companies’ actions.
Thought Leadership

Closing the Tax Gap? Corporate Tax Reform, the Courts and IRS Enforcement

March 30, 2011
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 compliance with Congress’ rules.
Thought Leadership

UK Budget 2011 - The Impact on Corporations With UK Operations

March 23, 2011
UK Budget 2011 has come at a critical time with the UK economy starting to show signs of improvement despite the downward revision of growth forecasts. The UK Chancellor stated at the outset of his speech that this would not be “a tax-raising budget” and there are some favourable measures.
Thought Leadership

The Expanding Nexus Landscape: A State Revenue Grab or a Swinging Pendulum?

March 23, 2011
With states facing unprecedented financial budget crises, every week we read about their efforts to generate more tax revenue. One popular trend has states looking to tax out-of-state companies by proposing broader nexus thresholds that would subject previously untaxed companies to the state’s tax.
Thought Leadership

The Bank Levy: A Fair and Substantial Contribution by the Financial Sector?

March 22, 2011
After the introduction of its Bank Levy at the start of 2011, the UK Government is already proposing a rate increase based on its assessment that the fiscal health of the banking industry may be in better shape than originally perceived. In addition to this, there is international pressure for a turnover tax on banks.
Thought Leadership

Maneuvering Through the IRS Employment Tax and Reporting Minefield

March 15, 2011
Companies have been bombarded: the Patient Protection and Affordable Care Act, the Wall Street Reform and Consumer Protection Act, the Tax Relief and Health Care Act, and the Small Business Jobs Act. It’s enough to make the most sophisticated of professionals want to run for cover. This edition of Tax Advisor Weekly shines some light on employment tax issues to keep on your radar for 2011.
Thought Leadership

A Closer Look at Proposed Corporate Tax Measures

March 9, 2011
The last few months have been significant in the world of Corporate Tax with the introduction of measures intended to make the UK’s system of taxation fairer, flatter, simpler and more competitive on the international stage under the snappily titled, “Corporate Tax Reform; delivery of a more competitive system” (the DNA of which goes back to a large extent to the 2005 Forsyth Tax Reform Commission).