Multinational Profits: Here, There, or Nowhere?

    ... Even for experienced international tax experts the technical and conceptual issues involved in determining where multinational profits should be located is enough to make one's head spin. ... Multinationals... are saying... that if a subsidiary...

    Invoking the Fifth - the House Oversight Inquisition

    Most readers will already know that Lois Lerner, a manager in the IRS division processing Section 501(c)(4) exempt organizations applications, invoked her 5th Amendment privilege in the House Oversight Committee public investigation (more akin to an inquisition...

    The IRS Is Broken, But That's the Symptom

    ... I... think, along with many others such as the Taxpayer Advocate, that the IRS is broken, and by that I mean it is so seriously messed-up that it is headed down a dangerous path that will turn it into a full-blown enforcement agency incapable of...

    See You Tuesday: IRS Furloughs Impact Deadlines & Services

    The IRS will be closed tomorrow [May 24th]. It is the first of five previously announced furlough days for the IRS brought on by federal budget cuts. While there may be some at the IRS who just want to get away , the long weekend may impact taxpayers...

    SCOTUS OKs U.K. Windfall Tax for Credit: The PPL Case

    The PPL decision was released yesterday [May 20, 2013] and taxprof posted initial thoughts from Reuven Avi Yonah and myself. I'm not convinced as Prof. Avi-Yonah is that the decision is correct, but I am interested in a few of the interpretive advances...

    Preview: Grilled Apple on the Menu

    ... [T] he tax policy issues that are subject of this [week's Senate Permanent Subcommittee on Investigation's [PSI] hearing on multinationals' cross-border profit shifting ] are enormous . Of all the big-money issues for corporations and...

    Scandal, Scandal, Scandal

    ... So, does the IRS's latest debacle rise to the level of scandal? I don't know yet; here's what I see so far. Among the many ridiculous tasks our politicians pile on the tax collector, the agency has been charged with determining whether...

    Lois Lerner Must Resign

    Why is Lois G. Lerner still on the taxpayer's payroll? Lerner is the director of exempt organizations whose failures are at the heart of the furor over indefensible criteria for selecting 501(c)(4) applicants for scrutiny. The Treasury Inspector General...

    Is the IRS Overzealous, Indifferent, or Both? Yes.

    Seems like only yesterday that Tea Party groups were the villains, not the victims, in stories about nonprofit political activity. Because it was yesterday, or close to it. For the last few days, Washington has been consumed by worry and indignation over...

    CFMA 2013 Annual Conference & Exhibition

    Construction Financial Management Association (CFMA) 2013 Annual Conference & Exhibition Conference Dates June 22-26, 2013 Location Hilton San Diego Bayfront San Diego, CA At CFMA's 2013 Annual Conference & Exhibition , attendees...

    John Doe Summons Issued to Wells Fargo for Records of CIBC FirstCaribbean International Bank Correspondent Account

    DOJ has announced, here , that a district court approved John Doe Summons for records of CIBC FirstCaribbean International Bank's correspondent account at Wells Fargo, N.A. The goal of the summons is to "allow the IRS to identify U.S. taxpayers...

    To Balance the Budget: Tax Sex Appeal

    Sometimes it is said all philosophy is a footnote to Plato. Perhaps it should also be said that all political satire is a footnote to the Irish clergyman Jonathan Swift . In his many works, Swift unmercifully challenges the status quo with unsurpassed...

    Dilemma - The Earned Income Tax Credit

    ... [T]he Obama Administration has demonstrated absolutely no interest in [tax reform]. But then there is the tax code, and the code itself is the biggest single challenge to reforming it. Our politicians have tried to do too much through the tax law...

    Bank Frey Executive and Swiss Lawyer Indicted

    The USA for SDNY has announced, here , the indictment of Stefan Buck, head of "Bank 1" (Bank Frey), and Edgar Paltzer, a partner at a Swiss law firm, a dual U.S.-Swiss citizen, and a registered attorney in NY. (A copy of the indictment is here...

    Valuation of Artwork for Federal Estate Tax Purposes

    Before valuing items of art, [ Estate of Elkins v. Comm'r , 2013 U.S. Tax Ct. LEXIS 6 (T.C. Mar. 11, 2013) ] held that pursuant to IRC Section 2703(a)(2) , the court would disregard an agreement made by the decedent by which he had waived his right...

    Securities Brokers Get Another Reporting Compliance Break

    IRC Section 6045 provides the broker reporting rules for certain securities, including debt instruments and options. Generally, for debt instruments acquired on or after January 1, 2013, brokers are required, when reporting the sale of the debt instrument...

    Promises, Promises

    ... In 2007 Senator Barack Obama, through a spokeswoman, called the AMT " outdated and in need of sustainable, long-term reform. He looks forward to working in a bipartisan fashion to reform the AMT in the future ." In his first budget for fiscal...

    It Just Isn't Fair

    The Government Accountability Office recently released a report on how much government revenue is left on the table because of "special tax provisions that are exceptions to the normal structure of the corporate income tax system." ... The...

    The Charity Deduction and Big Government

    When you filed your tax return, did you claim a deduction for charitable giving? Chances are pretty good that you did, since roughly 80 percent of itemizers do. The charity deduction is one of the oldest provisions of the income tax, dating from 1917...

    The Sentencing Sophisticated Means Enhancement Is Not Easy to Avoid

    The critical Sentencing Guidelines calculations for tax cases require a two step enhancement to the Base Offense Level for "sophisticated means" in the commission of the crime of conviction. S.G. 2T1.1(b)(2), here . Observers of the tax crimes...

    Hate Filing Your Tax Return? Good.

    Is there anything good about filing a tax return? For most of us, of course, it's a necessary ritual if we hope to stay on the right side of the law. And it certainly keeps the wheels turning for the federal government. But is there another, more...

    Two Weeks Left to File FICA Refund Claims

    The deadline for filing 2009 FICA refund claims based on U.S. v. Quality Stores, Inc. is fast approaching. Corporate taxpayers who experienced layoffs, reductions in force, and/or facility closures in 2009 or thereafter may file a protective refund claim...

    Principal Comments on Unclaimed Deductions and Losses in Sentencing Tax Loss Determinations

    The Sentencing Commission has received comments and testimony from principal constituents as to the issue of whether unclaimed deductions and credits should be permitted to reduce the tax loss in the critical tax loss calculation for sentencing purposes...

    A New Proposal to Promote American Manufacturing

    In recent years U.S. multinationals have restructured themselves in a manner that allows them to greatly reduce their worldwide tax bill. This restructuring has been described in detail by the OECD andil and by the Joint Committee on Taxation . In a March...

    Sequester Affecting Bonds

    IRC Section 6431 gives issuers of most qualified tax credit bonds the option of having their interest costs paid directly by the federal government in lieu of allowing federal tax credits to bondholders. The option is exercised through an irrevocable...