Partnership income allocation complexities are on the rise across the board. The aggregation rules are broken but should they be fixed or scrapped? Is there a practical solution?

When enacted this summer, Finance Bill 2011 will introduce significant changes to the longstanding chargeable gains rules on degrouping charges for assets, which can arise when a UK target is the subject of a share acquisition. In a recent amendment to the current Finance Bill, it will now be possible for taxpayers to elect for the new rules to apply to transactions carried out since 1 April 2011, rather than having to wait for Royal Assent.

As companies continue to look for ways to minimize IT infrastructure costs and gain the benefits of increasing technological advantages, Software as a Service (SaaS), or cloud computing, will continue to grow. Most states impose sales tax on the sale or transfer of tangible personal property, but a growing number of states tax services, including SaaS. With states facing budget shortfalls, more and more of them are exploring the possibility of taxing SaaS as a potential source of revenue.

Now that tax season is behind us and we have had a chance to catch our breath, the time has come to brush up on the constantly changing landscape of FBAR reporting.

In the current economic environment, many transfer pricing optimization strategies have come under heavy attack from both tax authorities and the general public. Strategies such as the migration of intangible property have historically been popular for large multinational corporations, but they are now being scrutinized heavily and can often result in disagreements between taxpayers and tax authorities (disagreements that have been well publicized).

The world of value-added tax is a rapidly changing environment.

As U.S.-based multinational corporations continue to expand global operations, supply chain initiatives are driving production and management functions increasingly to relatively low-cost jurisdictions.

In an economic environment that has dramatically changed over the past few years, transfer pricing is gaining more and more importance not just as a necessary evil (i.e., compliance with local legislation), but also as a planning tool to optimise a group’s tax effectiveness, thereby improving shareholder return.

The research credit continues to be an area of intense scrutiny during IRS examinations despite strong support from the President and Congress. One of the most common reasons for IRS disallowance of reported research credits is lack of substantiation, but preparing and organizing required research credit documentation is a time-consuming activity that can potentially overwhelm your tax department resources.

FATCA rules enforce international tax accountability.

A Google search for “corporate accountability” nets 534,000 hits (with this writing, make that 534,001). Heavy interest in the topic is unsurprising, given the numerous corporate upheavals, scandals and the like over the past few years. In a business climate of budget cuts, employee layoffs and widespread reporting of corporate losses, corporate officers have become lightning rods for criticism, with many commentators demanding that executives be held accountable for their companies’ actions.

In theory, the relationship between Congress, the Internal Revenue Service and corporate taxpayers is relatively simple. Congress enacts tax legislation, corporate taxpayers apply the Internal Revenue Code to their operations, and the IRS enforces compliance with Congress’ rules.

UK Budget 2011 has come at a critical time with the UK economy starting to show signs of improvement despite the downward revision of growth forecasts. The UK Chancellor stated at the outset of his speech that this would not be “a tax-raising budget” and there are some favourable measures.

With states facing unprecedented financial budget crises, every week we read about their efforts to generate more tax revenue. One popular trend has states looking to tax out-of-state companies by proposing broader nexus thresholds that would subject previously untaxed companies to the state’s tax.

After the introduction of its Bank Levy at the start of 2011, the UK Government is already proposing a rate increase based on its assessment that the fiscal health of the banking industry may be in better shape than originally perceived. In addition to this, there is international pressure for a turnover tax on banks.