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Thought Leadership

Supply Chain Planning: Narrowing the Gap between Tax and the Boardroom

June 10, 2011
Tax Directors often bemoan the fact that they are given very little face time with their boards. Being seen as “boffins” who sit silently at their desks, heads immersed in large books analysing pages and pages of legislation, hardly helps to secure that tantalising, career-changing invitation to the next board meeting. And, when they speak, their words are met with alarm: What is this alien language?
Thought Leadership

DOL Launching Attack on Late Filed and Incomplete Form 5500s

June 7, 2011
The Department of Labor has launched an aggressive program to determine whether companies are complying with the Form 5500 and associated audit report requirements in a timely way. The DOL is authorized to impose a penalty of up to $1,100 per day for noncompliance — which includes failure to timely file all or any part of the Form 5500. The recent electronic filing requirement has enabled the DOL to issue delinquency notices and assess penalties more efficiently than in the past.
Thought Leadership

Degrouping: The Tax Implications of Leaving a Corporation Tax Group

May 25, 2011
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.
Thought Leadership

Is Your Head in the Clouds? A Closer Look at the Taxability of Software as a Service

May 24, 2011
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.
Thought Leadership

Maximizing the Opportunity of Transfer Pricing Design through Centralized Procurement

May 11, 2011
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).
Thought Leadership

Working as an In-House Tax Team on Transfer Pricing

April 26, 2011
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.
Thought Leadership

Unforgiven: Lack of Proper Documentation Can Jeopardize Your Research Credit

April 21, 2011
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.
Thought Leadership

Covering Your Assets: Mitigating Officer Liability for Unpaid State Taxes

April 6, 2011
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.
Thought Leadership

Closing the Tax Gap? Corporate Tax Reform, the Courts and IRS Enforcement

March 30, 2011
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.
Thought Leadership

UK Budget 2011 - The Impact on Corporations With UK Operations

March 23, 2011
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.