Production Tax Credits: Credit Me for Generating Electricity with Renewable Energy Resources

UK Transfer pricing audits have been increasing steadily over the past decade. The trend is expected to continue in 2010, with some 1,000 outstanding cases at present related to UK transfer pricing. However, despite increased audit activity, the UK tax authorities are taking a measured approach to the selection of audits. This is encouraging for the many businesses that are making reasonable efforts to comply with the UK legislation.

HM Revenue & Customs (HMRC) has taken the unprecedented step of targeting medical professionals with another disclosure effort. This initiative follows the recent New Disclosure Opportunity (NDO), which was aimed at tax evasion relating to offshore bank accounts.

Section 199: 2010 Means More Bang for Your Domestic Production Buck

State Agencies Increase Audit Activity ... How to Manage the Audit Process

Recently, the federal government provided some relief to suffering businesses through the extension of the net operating loss (NOL) carryback. In a previous edition of Tax Advisor Weekly (, November 19, 2009), we noted that the carryback of a net operating loss would require a recalculation of the foreign tax credit limitation in those earlier years. As part of that analysis, or even apart from it, taxpayers may have the opportunity to re-evaluate decisions made in earlier years with respect to foreign taxes.

Many taxpayers have found themselves saddled with the inability to claim foreign tax credits. In large part, taxpayers who have an overall foreign loss (OFL) are subject to double taxation on any foreign earnings that become subject to U.S. taxation. Not only do lower tax rates abroad encourage foreign investment, but the inability to achieve relief under the U.S. foreign tax credit regime makes it prohibitively expensive for companies to repatriate such earnings.

One of the more confounding items that public companies must now deal with in the sales and use tax area is Financial Accounting Standards Statement Number 5 (FAS 5), Accounting for Contingencies.