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
Archive for Corporate
(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.
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.
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.
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.
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.
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!”
This week, the City Council in Portland, Oregon modified the business license tax for publicly traded companies subject to SEC reporting. Basically, before the change, this tax is 2.2% of adjusted net income (City Code 7.02.500). The new language increasing this for either a 10% or 24% surtax, follows:
On July 31, 2015, President Obama signed into law P.L. 114-41, the “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015,” which includes a number of important tax provisions, including revised due dates for partnership, S corporations and C corporation returns and revised extended due dates for some returns.
There is a lot of attention these days on big companies (Apple, Google, General Electric, Facebook and others) stashing their earnings overseas in what are considered tax havens to avoid paying U.S. taxes on their corporate income. Some international tax reform proposals have been suggested as to how to get the corporation to either bring this stash back into the U.S. by way of a “repatriation holiday” or “deemed repatriation” or ending the system of tax deferrals. Read more