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Thought Leadership

Maneuvering Through the IRS Employment Tax and Reporting Minefield

March 15, 2011
Companies have been bombarded: the Patient Protection and Affordable Care Act, the Wall Street Reform and Consumer Protection Act, the Tax Relief and Health Care Act, and the Small Business Jobs Act. It’s enough to make the most sophisticated of professionals want to run for cover. This edition of Tax Advisor Weekly shines some light on employment tax issues to keep on your radar for 2011.
Thought Leadership

A Closer Look at Proposed Corporate Tax Measures

March 9, 2011
The last few months have been significant in the world of Corporate Tax with the introduction of measures intended to make the UK’s system of taxation fairer, flatter, simpler and more competitive on the international stage under the snappily titled, “Corporate Tax Reform; delivery of a more competitive system” (the DNA of which goes back to a large extent to the 2005 Forsyth Tax Reform Commission).
Thought Leadership

Regulation Update

February 24, 2011
The need for even tighter banking regulations are attracting attention in the wake of recent scandals arising from the release of sensitive documents through websites such as Wikileaks. Despite a gradual erosion of the secrecy behind the once complex institutions, a new challenge has emerged. The recent prosecution of former Swiss banker Rudolf Elmer, who pled guilty to charges of infringing on his country’s strict banking confidentiality code, resulted in the Court’s decision to issue a modest financial penalty and a suspended sentence. Not only is the outcome disappointing to prosecutors, it serves as an unlikely deterrent for other individuals who choose to participate in similar illegal activities.
Thought Leadership

Tax Reform: Closer to a Reality?

February 23, 2011
This article is the first in a series that will address relevant considerations and provide insights when a change to U.S. corporate income tax laws or rates is anticipated. This first installment covers the financial statement considerations upon a change in tax law or rate. The second installment will address tax planning considerations in connection with an anticipated change in tax law or rate.
Thought Leadership

A Great Divide: 2011 Business and a 1959 State Tax Nexus Standard

February 15, 2011
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.”
Thought Leadership

2010 Legislative Update: A Stimulus Bonanza

February 11, 2011
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.
Thought Leadership

2011 and the Importance of Economic Substance

January 28, 2011
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.
Thought Leadership

Mayo Decision Places Challenges to Interpretive Treasury Regulations in the Line of Fire

January 26, 2011
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.
Thought Leadership

Forensic Accounting Due Diligence in M&A and Investment Transactions

January 19, 2011
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.
Thought Leadership

Gross-Ups: Down but Not Out

January 18, 2011
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.
Thought Leadership

Resolutions for Managing the Sales Tax Burden in 2011

January 5, 2011
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.
Thought Leadership

Research Credit Update: Compromise Provides Taxpayers with a Fistful of Dollars

December 22, 2010
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.
Thought Leadership

Some Income Tax Provision New Year's Resolutions

December 16, 2010
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.
Thought Leadership

News Flash: All States Are Unitary States

December 8, 2010
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.