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Archive for Corporate

How Should A Company Respond To IRS’s “Agreement of Facts” IDR?

Kevin Johnson, Tax Advisor

The IRS, within the last year or so, has begun issuing a final Information Document Request that requests the taxpayer to agree to underlying facts relating to an issue under audit (the Facts IDR).

My general advice to clients is to not respond to the Facts IDR.

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“Corporations Are People Too ….. My Friend.” – Tax Law

Giving a speech on tax reform whilst stumping for president in what is now seemingly a woebegone era of politics, Mitt Romney quipped this now seemingly famous sound bite personifying the greed of purported capitalism. According to US tax law, unfortunately he is right. Corporations are ‘treated’ like people.

Since this is how we live, when it comes to writing tax laws it seems a reasonable expectation that corporations behave as moral agents of society just like the rest of us. After all, they have their own decision structures and choices to make between rightness and wrongness, goodness and badness that are justified with reasons just like us. Read more

At-Risk Limitations (IRC § 465) Part 1

I am knee deep in another interesting file under dispute with our esteemed taxing authorities involving At-Risk Limitations. This is intended as the first of many posts on the topic as I navigate the shoals of a relatively complicated file that involves equipment leasing by a closely held C Corporation.

What are the At-Risk Rules? Read more

Tax Executives Facing Hiring Challenges With Millennials

As lead tax executives have been searching for tax managers at the eight to twelve year range, many are asking “ Where is the talent?” I was talking to a close friend of mine by the name of Dr. Mishe Serra who earned her doctorate at Harvard. She is an expert on generational thinkers such as millennials who think very differently than today’s Baby Boomer generation. In particular, I discussed an executive search experiences very close to me and I sought her advice on my messaging in order to help this client attract elusive talent. What I learned from Dr. Serra I want to share with you because it is important to understand what is happening. Dr. Serra is an expert on the topic of millennials and we will be getting her insightful work in the hands of executives who want to be enlightened on hiring trends in the tax profession. Read more

U.S. Government Agrees To Intervene In Apple’s €13B EU Case

Ron Marini

Apple has published its defense to the European Commission’s accusation that it obtained unfair commercial advantage from its corporation tax agreement with Ireland. Apple has published its defense to the European Commission’s accusation that it obtained unfair commercial advantage from its corporation tax agreement with Ireland.  Read more

Corporate Tax Executives: How To Get The Tax Team You Need

Kat Jennings

(This is a continuation of a series of posts focused on Corporate Taxes. To read the first article, click here.)

Leading a corporate tax organization is a complex and sophisticated role which requires an extraordinary effort on the part of tax executives today. Corporate tax executives today are leading teams across multiple times zones with ongoing tax deadlines and a schedule of expectations by management that is never ending. The opportunity to work with corporate tax executives over three decades has taught me a lot about this highly educated group of professionals.

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Unused LLCs And Corps

Why do you keep forming LLCs, partnerships or any kind of corporation when you’re not really ready to do business?

Then, you have these legal entities, with stringent tax filing responsibilities – and you do nothing.

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Big Businesses Lobby For 3.5% Offshore Repatriation Tax

Ron Marini

According to various news reports, U.S. multinationals are “pushing” the U.S. government to further reduce the tax rate on offshore profits. Major U.S. multinationals are pushing the Trump administration to deepen the tax break it has already tentatively proposed on $2.6 trillion in corporate profits being held offshore by more than 500 U.S. companies.

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Tax Court Rules For Amazon Against The IRS

Ron Marini

In 2015, Amazon was bitterly locked in a $1.5 billion transfer pricing dispute with the Internal Revenue Service over an arrangement it inked with a European subsidiary, and the outcome of the case, which is sitting in U.S. Tax Court, is being closely watched by multinationals and tax lawyers alike.

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Garlock: How Not To Structure A Controlled Foreign Corporation

Hale Stewart

A CFC is a foreign corporation where a U.S. shareholder owns “more than” 50% of the offshore company. Practitioners quickly noted the 50% ownership requirement and correctly deduced that, if a non-U.S. shareholder owned the remaining 50%, the foreign corporation could escape being a CFC.

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Income 54: Shareholders of Partnerships and S Corporations

John Dundon

The Colorado Department of Revenue has finally revised its guidelines in FYI Income 54 regarding people who do not live in Colorado but are partners and/or shareholders of partnerships and/or S corporations in Colorado, ensuring that pass-through entities pay Colorado income tax on their Colorado-source income. This Enrolled Agent says “About Time!”

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Canadian FAQ – Shareholders’ Equity – What You Need To Know!

Grant Gilmour

What is Shareholders’ Equity? Shareholders’ Equity is often used to measure the net worth of a company. It is used to assess the financial strength of a company.

Discussion:

Shareholders’ Equity (also commonly referred to as Owners’ Equity) comes from two sources:

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