State Tax Opportunities: Is There Green in Going Green?

A New Era in U.S. Withholding Tax and Foreign Account Reporting

What the country needs today is a Budget to mend the economy and a focus on cutting public spending at the right time. However, these measures do not go far enough.

Change in Estimate or Correction of an Error?

On 26 January, 2010, the IRS dropped a bombshell on US taxpayers with Announcement 2010-9, a new requirement which may have far reaching consequences for UK companies that file returns of subsidiaries or branches in the US. Additionally, US companies with UK subsidiaries may need to disclose uncertain UK tax positions on their US tax returns in specific circumstances. However, the international implications of the proposals were not addressed in the Announcement.

New York Corporate Tax Reform Proposals: Will You Be a Winner or a Loser?

Don't Get Left Out in the Cold: The FY 2011 Proposed Budget and Its Blizzard of Changes

Production Tax Credits: Credit Me for Generating Electricity with Renewable Energy Resources

UK Transfer pricing audits have been increasing steadily over the past decade. The trend is expected to continue in 2010, with some 1,000 outstanding cases at present related to UK transfer pricing. However, despite increased audit activity, the UK tax authorities are taking a measured approach to the selection of audits. This is encouraging for the many businesses that are making reasonable efforts to comply with the UK legislation.

HM Revenue & Customs (HMRC) has taken the unprecedented step of targeting medical professionals with another disclosure effort. This initiative follows the recent New Disclosure Opportunity (NDO), which was aimed at tax evasion relating to offshore bank accounts.

Section 199: 2010 Means More Bang for Your Domestic Production Buck

State Agencies Increase Audit Activity ... How to Manage the Audit Process

Recently, the federal government provided some relief to suffering businesses through the extension of the net operating loss (NOL) carryback. In a previous edition of Tax Advisor Weekly (, November 19, 2009), we noted that the carryback of a net operating loss would require a recalculation of the foreign tax credit limitation in those earlier years. As part of that analysis, or even apart from it, taxpayers may have the opportunity to re-evaluate decisions made in earlier years with respect to foreign taxes.

Many taxpayers have found themselves saddled with the inability to claim foreign tax credits. In large part, taxpayers who have an overall foreign loss (OFL) are subject to double taxation on any foreign earnings that become subject to U.S. taxation. Not only do lower tax rates abroad encourage foreign investment, but the inability to achieve relief under the U.S. foreign tax credit regime makes it prohibitively expensive for companies to repatriate such earnings.