It is widely held that the reality of a transaction should ultimately govern when interpreting the meaning of a contractual arrangement. The "substance over form" doctrine, which originated under the Supreme Court's ruling in Gregory v. Helvering, is frequently invoked by tax authorities to frame the interpretation of a contractual arrangement whose meaning is called into question.

"Give someone an inch and they'll take a mile." Although this phrase is usually not associated with state taxation, perhaps it should be. More specifically, in the absence of guidance from the United States Supreme Court, states have sometimes taken the inch they have been given in determining what activities are sufficient to constitute nexus for income tax purposes and stretched this inch into a mile.

In recent years an increasing number of post-merger and acquisition disputes have been triggered by the financial performance of target companies performing below buyers' expectations. In these situations, representations and warranties may not justify a cause of action or may include caps prohibiting a claim that would cover the economic loss.

For years, the collective wisdom has been that flow-through entities such as partnerships and S corporations are rarely audited. We still regularly hear that comment in the marketplace. However, this is no longer the case. In fact, several years ago the IRS identified high-wealth individuals as an area of audit emphasis, and the partnerships in which many of these individuals invest have also come under additional scrutiny.

In the popular series "Where in the World Is Carmen Sandiego?" Carmen is an international thief who sneaks around the world dodging the crime-fighting moves of her followers while leaving behind fundamental lessons of math, geography and other subjects in her wake.

Borrowing trends and the overall economic environment have undergone notable changes, prompting the UK tax authority (HMRC) to set out guidance for Tax Inspectors when selecting cases for audit.

Day after day, we read reports of disconcerting financial and economic events worldwide. Certainly, Europe takes the lead with its continuing problems of financial system instability.

Companies often deduct their annual bonus expense the year prior to paying the bonus. But should they? The answer is not clear, and the IRS has changed its position on this issue.

Does your company qualify as a manufacturer?

The election of Francois Hollande as President of France has sparked a debate in the Euro-zone on austerity and growth. Those who argue for austerity or ‘fiscal prudence' claim that debt management is key to restoring investor confidence and, therefore, long-term prosperity. Borrowing more is not an acceptable response to a crisis caused by over-borrowing and over-spending. In contrast, those who prefer greater stimulus claim that, without further investment, growth will simply not return, and without some government stimulus, no economy can pull itself out of recession to achieve long-term stability and growth.

A business or intangible asset is typically valued using a combination of the income, market and asset approaches. A valuation conducted specifically for tax purposes introduces added layers of complexity due to nuances specific to this type of valuation, often causing critical assumptions and values to differ from valuations conducted for other purposes.