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.

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.