FATCA rules enforce international tax accountability.

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.

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.

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.

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.

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.

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.

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).

In an effort to resolve some of the long-standing controversies between taxpayers and the IRS on research credit issues, the IRS hosted a discussion forum with tax practitioners on January 5 and January 6, 2011 in Washington, D.C. The primary focus of the workshop was the nexus issue for the research credit.

The need for even tighter banking regulations are attracting attention in the wake of recent scandals arising from the release of sensitive documents through websites such as Wikileaks. Despite a gradual erosion of the secrecy behind the once complex institutions, a new challenge has emerged. The recent prosecution of former Swiss banker Rudolf Elmer, who pled guilty to charges of infringing on his country’s strict banking confidentiality code, resulted in the Court’s decision to issue a modest financial penalty and a suspended sentence. Not only is the outcome disappointing to prosecutors, it serves as an unlikely deterrent for other individuals who choose to participate in similar illegal activities.

This article is the first in a series that will address relevant considerations and provide insights when a change to U.S. corporate income tax laws or rates is anticipated. This first installment covers the financial statement considerations upon a change in tax law or rate. The second installment will address tax planning considerations in connection with an anticipated change in tax law or rate.

There are examples of states and taxpayers framing issues and drawing conclusions with a modern view of P.L. 86-272. There are more, however, that rely on strict construction — a more articulate way of saying “head in the sand” or “tunnel vision.”

The 2010 Tax Relief Act includes a variety of significant tax relief measures for individuals. Key measures for individuals include a two-year extension of the 2001 and 2003 tax cuts, an extension of the alternative minimum tax “patch” through 2011 and a one-year payroll tax reduction (“holiday”) for employees.

Transfer pricing issues faced by multinational businesses have been exacerbated in recent years by the introduction of new legislation and a legion of global transfer pricing disputes with tax administrations. However, significant savings can be achieved with effective tax planning involving transfer pricing design supported by economic analysis.

As discussed below, Mayo is the culmination of three decades of agency administrative law review decisions by the Supreme Court. Mayo is the end result of increasing judicial deference to IRS and other federal agency regulations. The decision could have broad implications not just for taxpayers dealing with IRS regulations, but for the entire field of administrative law.