In light of the impending global war for corporate tax revenue, this article outlines an audit strategy based on the Eight Rules of Air Combat written for fighter pilots in World War I and applies four of those rules to help companies prepare for tax audits in order to favorably resolve tax controversies.

For many companies, it happens every three to four years like clockwork — you receive a questionnaire or letter with those infamous words "you have been selected for a sales and use tax audit.

It’s a tale as old as time itself: Buyer meets seller. Buyer falls in love with seller’s business. Buyer proposes to seller.

Restaurants continue to be attractive targets for investors and strategic acquirers as many eateries offer appealing ways to deploy capital and diversify. In fact, there were 132 announced restaurant transactions in 2013; and activity remained strong throughout the first quarter of 2014 with 31 announced restaurant transactions, according to S&P Capital IQ. However, savvy investors must understand the unique accounting considerations associated with restaurants, and carefully include operational improvement and other initiatives into any investment thesis.

Software-as-a-Service (SaaS)1 is no longer an emerging technology segment. It’s big and getting bigger – and here to stay. The technology research and advisory firm IDC predicts that spending on private cloud services will grow from $9 billion in 2013 to $24 billion in 20162 – and public IT cloud services spending will grow from $47 billion in 2013 to $107 billion in 2017.3

This edition of Tax Advisor Weekly is a follow-up to an article previously posted, “Entity Simplification: Not So Simple (But Likely Beneficial).”

As we noted, research that is reimbursed by your customers can qualify if, pursuant to the contract, you are economically at risk and you retain substantial rights in the research conducted.

Merger and acquisition cycles are fueled by many forces, not least among them being the strategies promoted by activist investors and investment banking advisors. Once in favor, conglomerates dotted the industrial landscape. However, within the past several years, the scale, adjacent market synergies and potential integration benefits of an aggregation strategy have been counter-balanced by arguments for better management focus and clearer market / equity analyst communications.

One of the few recent taxpayer-favorable decisions could have a significant impact on more than just homebuilders in similar situations.

Executive compensation continues to be a hot topic for politicians, shareholders, shareholder advisory firms and the media. A major point of contention for these groups revolves around benefits provided to executives in connection with a change in control, commonly called "golden parachutes."

The increased focus of the UK Tax Administration (HMRC) on transfer pricing has led to a noticeable increase in the number of businesses seeking the certainty of transfer pricing arrangements through an Advance Pricing Agreement (APA) or an Advanced Thin Capitalisation Agreement (ATCA).

Generally, the sale or exchange of an interest in a partnership is treated as the sale or exchange of a capital asset, and therefore resulting gains and losses are capital (IRC Section 741). This is fine if you recognize gains, but not so great for the losses. What if the loss on the disposition of a partnership interest could be ordinary? Would you have a different feeling about triggering the loss?

It remains hard to say whether the IRS will challenge your transaction by asserting the economic substance doctrine, because the IRS said in December it won’t be issuing anticipated further guidance or an angel list.