Economic Substance Doctrine: Clarification or Mere Codification?

Captive insurance companies have been a widely used enterprise risk management tool. Many corporations have used captive insurance companies to manage risks that commercial markets either don’t address cost effectively or may not address at all.

Trail Blazers in Oregon: From the Tax Court, Not the Hard Court

Multinational businesses have extensively applied the use of tax effective procurement companies to deliver efficiencies in the sourcing of goods and materials to achieve fiscal benefits. However, businesses are often resistant to significant operational change across the entire supply chain as it can prove to be costly and time consuming. Procurement, on the other hand, offers an opportunity to achieve supply chain savings through a single process.

Mandatory Combined Reporting: States Try to Find the Right (Forced) Combination to Unlock Additional Revenue

The New Dispute Resolution Panel: A Ray of Hope for Indian Taxpayers

We are sure that you're aware of Internal Revenue Code Section 409A, which altered the way employers are permitted to structure their deferred compensation plans. All nonqualified deferred compensation arrangements had to be amended to comply in form with and be operating in compliance with the Final Treasury Regulations by December 31, 2008. The consequences of a failure to comply are steep: a 20 percent excise tax and interest levied on the employee.

In the past few months, there have been developments in the European VAT courts that could have significant implications for businesses involved in M&A activity, as well as corporate groups in general.

State Tax Opportunities: Is There Green in Going Green?

A New Era in U.S. Withholding Tax and Foreign Account Reporting

What the country needs today is a Budget to mend the economy and a focus on cutting public spending at the right time. However, these measures do not go far enough.

Change in Estimate or Correction of an Error?

On 26 January, 2010, the IRS dropped a bombshell on US taxpayers with Announcement 2010-9, a new requirement which may have far reaching consequences for UK companies that file returns of subsidiaries or branches in the US. Additionally, US companies with UK subsidiaries may need to disclose uncertain UK tax positions on their US tax returns in specific circumstances. However, the international implications of the proposals were not addressed in the Announcement.

New York Corporate Tax Reform Proposals: Will You Be a Winner or a Loser?

Don't Get Left Out in the Cold: The FY 2011 Proposed Budget and Its Blizzard of Changes