Tax Law

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View all the federal, state and international tax news headlines for October 10th from TaxAnalysts® on LexisNexis Tax Center
Posted on 10 Oct 2013 by TaxAnalysts®

View all the federal tax news headlines for October 10th from TaxAnalysts® on LexisNexis Tax Center View all the state tax news headlines for October 10th from TaxAnalysts® on LexisNexis Tax Center View all the international tax news headlines... Read More

Filing Compliance Procedures Challenge U.S. Taxpayers Residing Overseas
Posted on 22 Oct 2014 by Rufus v. Rhoades & Alexey Manasuev

Generally, [the 2012 Offshore Voluntary Disclosure Program] OVDP is designed for those delinquent U.S. taxpayers who have been holding financial assets overseas, have not been disclosing such assets to the U.S. government, have not been reporting... Read More

'Legal Enemies of the State'!
Posted on 29 Mar 2013 by Christopher Bergin

How does that old Wall Street saying go? Bulls make money; Bears make money; Pigs get slaughtered. Bulls in this context are easily defined, and so are Bears. Money can be measured. But it seems to me that piggy behavior is in the eyes of the beholder... Read More

How Important Is Deferral to Multinationals?
Posted on 22 Apr 2013 by TaxAnalysts®

by Jeremy Scott The U.S. tax system allows multinationals to effectively indefinitely defer taxes on profits earned by active foreign affiliates until that money is repatriated to the United States. Deferral as a cornerstone of tax policy dates from... Read More

FATCA Compliance Programs
Posted on 24 Mar 2014 by William H. Byrnes IV

By Prof. William H. Byrnes and Dr. Robert J. Munro * Editor's Note: The following is an excerpt from Chapter 2 of the 2014 edition of LexisNexis Guide to LexisNexis® Guide to FATCA Compliance by William Byrnes and Robert Munro, published February... Read More

A Moral Obligation to Aggressively Lobby
Posted on 1 Mar 2013 by Martin A. Sullivan

In the United Kingdom a great debate is taking place about aggressive tax avoidance. On one side, David Cameron, the Conservative prime minister, says it is immoral . On the other side, most executives say they have a duty to their shareholders, and most... Read More

Strengthening Procedures Against Tax Evasion
Posted on 20 Nov 2013 by Henry (Terry) Christensen III, Esq.

by Henry Christensen III * The events involving Union Bank of Switzerland ("UBS") have resulted in federal criminal prosecutions, a deferred prosecution agreement between the U.S. Department of Justice and UBS and a separate global settlement... Read More

View all the federal, state and international tax news headlines for April 14th from TaxAnalysts® on LexisNexis Tax Center
Posted on 14 Apr 2014 by TaxAnalysts®

View all the federal tax news headlines for April 14th from TaxAnalysts® on LexisNexis Tax Center View all the state tax news headlines for April 14th from TaxAnalysts® on LexisNexis Tax Center View all the international tax news headlines... Read More

Repatriation Tax Holidays and IRC Section 965
Posted on 11 Jul 2012 by LexisNexis Tax Law Community Staff

By Mary Riley * The debate over corporate tax reform has largely centered on lowering the corporate tax rate and, more radically, transitioning from a worldwide to a territorial system of international taxation. [Donald J. Marples and Jane G. Gravelle... Read More

NYU Summer Institute in Taxation
Posted on 7 Jul 2014 by NYU School of Continuing & Professional Studie

Dates: July 14-25, 2014 Location: The Westin New York at Times Square New York, NY Join today's leading national and international tax authorities during a series of in-depth sessions on state and local taxation, partnerships, consolidated returns... Read More

SCOTUS OKs U.K. Windfall Tax for Credit: The PPL Case
Posted on 21 May 2013 by Allison Christians

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... Read More

Tax Considerations for Taxpayers Applying the Economic Substance Doctrine
Posted on 5 Apr 2012 by Rufus v. Rhoades & Alexey Manasuev

The Background In 2010, Congress codified the economic substance doctrine, but left numerous unanswered questions for taxpayers on how to apply the doctrine. Along with codifying the economic substance doctrine, Congress also enacted strict liability... Read More

Corporate Tax Transparency
Posted on 12 Apr 2012 by Allison Christians

The activist-led movement to increase multinational tax disclosure is proving to be a full-employment program for natural resource industry lobbyists. The money and energy available for fighting against transparency seems limitless. We have seen the effects... Read More

Will Developed Countries Learn to Tax?
Posted on 6 Mar 2012 by Allison Christians

In 1963, Nicholas Kaldor published a paper in Foreign Affairs about the ongoing fiscal problems of poor countries, entitled " Will Underdeveloped Countries Learn to Tax? " It turns out Kaldor should have aimed this advice at his own country... Read More

Managing the Competent Authority Process for U.S.-Based Multinational Enterprises
Posted on 13 Feb 2013 by LexisNexis Tax Law Community Staff

by Barry Shott, Richard Barrett and Elizabeth Sweigart * Under pressure to close revenue gaps and to address perceived aggressive tax positions related to the pricing of cross-border transactions, both the U.S. and foreign tax authorities are imposing... Read More