The Tax Court rejected the IRS proposed transfer pricing method of re-allocating income between a U.S. parent corporation and its foreign subsidiary. Also, it ruled against the Service’s attempt to collect $1.36 billion in tax deficiencies, finding that the assessment did not reflect the economic realities of manufacturing these medical devices in a case involving Medtronic’s intellectual property licenses necessary to produce and sell high-risk, heavily regulated implantable technology.
Archive for Corporate
Regardless of how your tax team is organized, managing a tax organization across multiple locations is always a challenge. Even the most savvy management executives seek to find innovative ways to make people feel more connected. Whether you have a corporate tax team of 200 spread across 50 countries, or a corporate tax team of 10 spread across 3 countries; you must always strive to be creative to be effective. Years ago, everyone in the tax department was expected to be working in the same location; and now things have progressed to managing geographically dispersed teams. Read more
College and high school students are frequently utilized by businesses and non-profit organizations as interns. These arrangements can be beneficial to the organization as the organization may get the services and insights from the intern, even though the organization receives no immediate tangible benefit. The intern may benefit by obtaining valuable on-the-job training, an entree into a permanent job, college credit, and maybe a few dollars in earnings. Internships vary greatly. They may be paid or unpaid; for college credit or not for credit; highly structured as in a college program, or an independent arrangement with less structure. Read more
Strategies that motivate management to listen to the Tax Department is what we will address in this week’s post. Although there are dozens of topics I could address, this post will address a couple of challenges faced by most anyone leading a tax organization when it comes to compensating your tax team. This post will also provide solutions; these are solutions intended to make your job leading a tax organization easier. Although I know better than to put “ Head of Tax” and “Easy” in the same line, leading a tax organization is one of the toughest jobs out there today. Read more
According to Law360 (subscription required), an ex-managing director at corporate acquisition business MidCoast Financial Inc. was found not guilty by a Pennsylvania federal jury on Wednesday over his alleged involvement in a complex $200 million corporate tax fraud scheme.
Donald Stevenson of North Palm Beach, Fla., 58, was cleared after a six-day trial on charges that he conspired to defraud the U.S. and corruptly endeavored to obstruct and impede the due administration of Internal Revenue Service laws. Stevenson, the only defendant to be acquitted in the scheme, faced 8 years in prison.
Federal prosecutors alleged that Stevenson and others conjured up and participated in an elaborate scheme Read more
The 2015 Federal Budget proposals to section 55 may cause otherwise tax free inter-corporate dividends to be subject to taxation as proceeds of disposition (ie., capital gains) that previously were exempt from the ambeit of section 55. Computation of safe income or post-1971 tax retained earnings may now be required in every instance to ensure one is not caught. Timely section 55(5)(f) designations filed by the recipient corporation may also have to be made. The proposal was to be effective for dividends paid after April 20, 2015. Hopefully there will be further consultation on the matter and the final legislation will only affect those circumstances to which the proposal was intended.
Caution should be made to companies currently paying dividends or wishing to implement various purification techniques, capital gains crystallization and other restructuring that may involve section 55 of the Income Tax Act Read more
After thousands of interviews and valuable successes finding the best in the tax profession through http://www.etsearch.com/clients.htm, we evolved into our new entity www.taxconnections.com. Through all the successes, what was most important were the lessons learned from every lead tax executive I encountered in a corporation. Recently, I was reminded how valuable tax executives are while talking to nationally recognized tax expert Dan Thompson of Thompson Tax & Associates headquartered in San Francisco, California. Dan sent me a video in the day of a life of a Tax Director. In the video, he started out by saying “You are a Tax Director and you walk into the office one day and the State & Local Tax Manager tells you the State Auditors want to conduct an audit in an hour on an issue that has been overlooked. A few moments later with a cup of coffee in hand, the Read more
Over the years, I have completed several private studies for corporations who were benchmarking salaries for their tax departments. The purpose of this post is to educate you on how to obtain the most accurate and up-to-date information for your tax department. Allow me to set guidelines and boundaries right up front and that means how the information is gathered. First of all, the mass produced surveys of tax professionals by well-known staffing houses are so far off the mark that they often do a great disservice to those who read them. You must have a person who understands tax and the role each tax professional plays in an organization.
There are hundreds of unique tax positions around the world within specialized areas of taxation; unless you understand the complexity of technical skills involved you are Read more
A CEO of a privately-held company contacted me recently about their Head of Tax retiring. I call the Head of Tax or VP Tax by the acronym “HOT” because the great ones are really on fire when it comes to saving a company revenue that otherwise would be lost forever. In this case, the company CEO hired the Head of Tax many years ago and what was remarkable was the CEO deeply appreciated and valued their work. He recognized the VP Tax saved the company hundreds of millions over the years; he recognized the value the VP Tax brought to the organization overall. It was refreshing to be part of this conversation and listening to the CEO discuss his sincere appreciation for the outstanding contributions of the VP Tax. Frankly, it is not too often that I hear a CEO talk about how much they appreciated and admired their Head of Tax. Whenever I do hear these Read more
For those CFOs who have yet to discover the true value of the corporate tax department, I will give you a crash course on this valuable asset. Allow me to boldly state that I am an expert on what can go wrong and what can go right in your corporate tax department. How would I even know? Thirty plus years as an internationally recognized tax headhunter placing tax executives in multinational corporations all over the world through http://www.etsearch.com/clients.htm which has now been folded into my second company www.taxconnections.com executive search division. After hundreds of thousands of trusted and private conversations with tax professionals, I am an expert counsel to tax executives worldwide searching for corporate tax jobs.
What I will share with you today are real stories from corporate tax leaders, the stories no Read more
September 15 – Corporations
File a 2014 calendar year income tax return (Form 1120 or 1120-A) and pay any tax, interest, and penalties due. This due date applies only if you timely requested an automatic 6-month extension.
September 15 – S Corporations
File a 2014 calendar year income tax return (Form 1120S) and pay any tax due. This due date applies only if you requested an automatic 6-month extension.
September 15 – Corporations Read more
If you have a calendar year 2014 partnership, S-corporation, or trust return on extension, don’t forget the extension for filing those returns ends on September 15, 2015.
Pass-through entities such as Partnerships, S-corporations, and fiduciaries (trusts, estates) pass their income, deductions, credits, etc., through to their investors, partners, or beneficiaries, who in turn report the various items on their individual tax returns. Partnerships file Form 1065, S-corps file Form 1120-S, and Fiduciaries file Form 1041, with each partner, shareholder, or beneficiary receiving a Schedule K-1 from the entity that shows their share of the reportable items.
If all of the aforementioned entities could obtain an automatic extension to file their returns Read more