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.

The Internal Revenue Service recently published draft proposed guidance on the competent authority process in the form of Notice 2013-78.

2014 will be the year to be a multinational enterprise in the UK. Corporation tax rates are on the decline to the lowest within the G8, and general economic growth has returned.

The Information Document Request (IDR) process that we have all followed in a typical IRS audit in the past has recently undergone some substantial changes that will require an evaluation of your current process for dealing with such requests and managing the overall audit process.

A common refrain heard through the course of one’s life is that you should always look out for your own best interests, because no one else will.

The release of the much anticipated final “repair” regulations (Treasury Decision 9636) in September probably stands as the most significant federal tax development of 2013. At over 200 pages in length, the regulations cover a gamut of capitalization questions that are expected to affect nearly every taxpayer.

Draft Finance Bill 2014 was released today with a number of changes that will be important for businesses to recognise. A&M Taxand UK will be responding to the UK Tax Authorities with suggested improvements. This consultation process functions effectively and we ask clients to send us any submissions that they would like us to take forward by the deadline of 4 February 2014.

Various factors such as the growing complexity of U.S. tax laws and compliance obligations, looming corporate tax reform at home and abroad, and the growing role of international operations have made year-end planning more complicated with every passing year. This edition of Tax Advisor Weekly highlights some of the technical developments that occurred in 2013 and important deadlines for 2014, but at the same time provides an approach that tax departments can follow as they tackle year-end planning for their company.

As 2013 comes to an end and our thoughts turn to the holidays, here are a few compensation planning opportunities that should be considered.

Remaining competitive from a tax perspective is a top priority for the UK but the Tax Authorities are also seeking to increase tax revenues where possible.