The UK Tax Authority (HMRC) recently published a statistical study on transfer pricing (TP) trends in relation to the audit process, Advanced Pricing Agreements (APAs), Advanced Thin Cap Agreements (ATCAs) and Mutual Agreement Procedures (MAPs). A look at the results provides a good indication of where HMRC is focusing efforts and what UK businesses need to know about TP audits.

With the pervasiveness of cloud computing, you may have witnessed a state tax assessor acting on an extreme tax position in an effort to apply dated tax concepts to a technological new world. Tax treatment varies from state to state, and some states’ positions make logical sense, while others are difficult to fathom.

Sales and use tax compliance is not a simple process. In the United States, there are over 11,000 taxing authorities with constantly changing sales tax rates and laws.

Since the collapse of Enron, Congress has been ratcheting up laws encouraging insiders to rat out financial wrongdoers and tax cheats by offering substantial mandatory cash bounties for information leading to additional tax collections, penalties or other monetary sanctions.

Executive compensation remains under the microscope of politicians, shareholders and shareholder advisory firms. A major point of contention revolves around benefits provided to executives in connection with a change in control. Surprisingly, these benefits increased during the last few years, driven primarily by the recovery in the stock market.

Section 382 can best be described as an intricate construct that usually numbs the mind with its complexity and often baffles the senses with its result.

Just in time for the holidays, the IRS released new temporary regulations addressing the treatment of expenditures for tangible property.

Many buyers and sellers of businesses do not consider state income tax consequences until after a deal has been completed. Ignoring state tax considerations at the outset of a transaction may put you in an adverse negotiation position, particularly in a deemed asset sale under Internal Revenue Code (IRC) Section 338(h)(10). It may come as a surprise that significant state taxes can result from such an election.

As businesses increasingly rely on rapidly evolving remote or outsourced information technology (IT) accessed via the internet (colloquially called “The Cloud”), tax planning in general enters into relatively new territory as well. Setting transfer prices for related-party transactions that have the effect of allocating profits among competing taxing jurisdictions is no exception.

There is a common view among nations that it is essential to provide business enterprises with tax incentives to perform R&D activities within a nation's borders, and that these incentives are an important driver for a nation's economic future.

When you think of unclaimed property and escheatment, a bank or insurance company probably comes to mind as the type of business that would be concerned with tracking and reporting items of unclaimed property. However, although state unclaimed property laws were first established because of banks and insurance companies, they now have a much broader reach and are applicable to many types of businesses.