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.

The economic forecast for 2011 predicts continued recovery, and many corporations that have amassed significant cash balances are stepping up the search for savvy investments. As a result, merger and acquisition (M&A) activity, as well as funding available to private equity funds and other investors, is expected to increase.

With the U.S. national unemployment rate lingering above 9 percent, many are trying to identify the issues responsible for the current situation. Often, the blame is placed on excessive executive compensation.

Most of us decide at the beginning of a new year to set resolutions...lose weight, better manage finances or improve ourselves in some other way. As we know, New Year’s resolutions are fairly easy to make but very difficult to maintain. The same holds true for resolutions to improve operations at your company. With the economy still in flux and new state legislatures about to convene, now may be the best time to put into place some practices that will improve your tax department’s efficiency and effectiveness.

The tax compromise signed into law by President Obama this past Friday includes a variety of individual and business tax relief measures, ranging from the much debated 35 percent top tax rate for estate taxes through 2012, to numerous benefits for businesses, such as the 100 percent first-year bonus depreciation for investments in certain machinery and equipment placed in service prior to January 1, 2012. The compromise also notably includes a two-year extension of the federal research credit, for calendar years 2010 and 2011.

December can be a busy month. The holidays and the decorating, the airports and the travelling, and — for some tax departments — preparing for the year-end income tax provision crunch soon to come.

Each year, many taxpayers file inaccurate corporate income tax returns in separate-reporting jurisdictions because they do not consider the unitary business principle applicable to those states.

A&M recently sat down with HMRC’s new Head of Transfer Pricing to discuss current trends and pass on client concerns.

Given the weak U.S. economic recovery, the results of the mid-term elections and the lame duck tax issues still to be addressed before year-end, the next month will likely further transform the tax system.

Do your foreign affiliates earn income from sources within the United States but otherwise do not have a presence in the U.S.? Do you think you are not subject to state income tax? Then this article is a must read for you.

Provision – as reporting deadlines draw near, the very word can be enough to cast doubt in the minds of the most seasoned tax professionals. There is a certain sense of uneasiness that can start to grow over the holiday period as tax departments around the world look forward to some late nights crunching the numbers into the New Year. If the year end process at your company is hanging over yourtax department like the fabled sword of Damocles then read on.

On July 21, 2010, President Obama signed the financial regulatory reform bill (Dodd-Frank Act) into law, which created a permanent exemption of Section 404(b) of the Sarbanes-Oxley Act of 2002 (SOX(b)) for issuers with market capitalization of less than $75 million.

As banks and other lenders begin to come to grips with working out some of their underperforming loan books, we are seeing an increasing number of transactions that involve the acquisition of target companies that cannot repay their borrowings. In this issue of Tax Adviser Update (TAU), Ian Fleming and Jonathan Hornby provide an update on taxation developments in this area and share some experiences from recent transactions.

The internet and other forms of multimedia have made connecting with distant parts of the globe as easy as clicking a button, and as a result of this access, the ability of individuals to interact with numerous global markets has greatly increased.

Washington State Changes B&O Tax Law for Service Businesses