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IRS Charges $113,500 Fee To Review Your Transfer Pricing Methodology Prior To Filing Corporate Tax Return

IRS Charges $113,500 To Review Your Transfer Pricing Methodology

We found this important information on the IRS site…while most multinational corporate tax executives are aware of this fee, there are many company executives who are unaware of the costs of transfer pricing when they hire a transfer pricing consultant. Contact us for referrals to TaxConnections Members who are experts in transfer pricing: 

Consider if…
Prior to filing a return, you seek tax certainty and the avoidance of a transfer pricing dispute with the IRS and one or more treaty partner administrations by securing an agreement on a transfer pricing methodology. In an APA, the IRS and one or more foreign tax administrations come to an agreement with the taxpayer on: (1) the factual nature of the inter-company transaction to which the APA applies; (2) an appropriate transfer pricing method (“TPM”) to be applied to any allocation of income, deductions credits or allowances among two or more controlled organizations; and (3) an expected range of results from applying the TPM to the transactions. This program is designed to promptly and fairly resolve APA requests based on principled and cooperative negotiations between the IRS, treaty partner tax administrations, and the taxpayer.

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Taxable Values: Don’t Be Afraid To Appeal

Taxable Values: Don’t Be Afraid to Appeal

Taxable Values Overview

Every year companies must file business personal property returns to the various local taxing authorities where they hold assets. These returns determine the taxable values that those authorities use to calculate your annual business property tax. Most jurisdictions, upon receipt of the return, calculate an assessment or taxable value and generate a notice that they mail to the various businesses. This amount is then applied to the authority’s tax rate to give you your tax amount for the year. It is vital for a business to know and understand how that amount is determined so they are not being over or under assessed on their property taxes. No one wants to overpay if they don’t have to, and I can’t imagine any business would like to be audited and get charged penalties and interest because they weren’t aware that their amounts were being calculated incorrectly.

Receiving Your Assessment Notice

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Very Important Alert To CFOs And Lead Tax Executives: Add Tax Expertise To Multinational Corporations Now

Private Conversations With Tax Professionals: What They Have Shared With Me About Working In This New Environment

This Informational Gift will increase the success of every CEO, CFO And Head Of Tax who is proactive with this message.

The G7 just agreed to a 15% minimum corporate tax rate. You may have been in your Executive role 2 months, 2 years, or 20 years. What I am about to share with you is an informational gift that will help you get it right, give you job security, and place you ahead of competitors.

For more than three decades, corporate clients have stayed in contact with me because they know my reputation for searching for and finding the very best tax experts around the world. The discussions I have with leading tax experts are extraordinarily valuable!

The G7 Agreement to a 15% minimum corporate tax rate will turn Corporate Executives (CEOs, CFOs, Head of Tax) lives upside down.

A retired Tax Partner of an international law firm, a former CPA with a national accounting firm, and a Head of Tax of a multinational corporation, who never lost an IRS transfer pricing controversy, told me recently what this means for companies and CFOs. He stated that multinational company transfer pricing methodologies will now be exposed for shifting profits and claiming certain functions are performed in countries they are not. He said companies are kidding themselves if they are unaware of their transfer pricing exposure. The G7 agreement to a 15% tax is a minimum tax and it is an advance tax payment against future taxes. It is not an add to tax but in essence an advanced tax payment.

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Want To Find A Tax Job? Join Me In Private Discussion On How To Find A Tax Job

Want To Find A Tax Job? Join Me In Private Discussion On How To Find A Tax Job - Saturday, June 12, 2021

Given the number of calls received about finding a tax job, I am inviting tax professionals interested in learning the answer to the following questions into a conference call. This conference call will be limited to thirty tax professionals who will have privacy and anonymity during the call. The purpose is to help you understand what is happening in the job market and provide you information that is generally unavailable to most people.

This private session will be held on Saturday morning and the first session will be held on Saturday June 12, 2021 at 8:00AM to 9:00AM California time/11:00AM to 12:00PM New York Time.

Here are the topics to be discussed tomorrow so make your request  now if you would like to be given access to this private conference.

  1. What does the job market look like for tax professionals?
  2. What can I do to increase my chances of being hired?
    3. When I submit my resume companies never call me back. What should I do as a follow up?
  3. What can I do to increase my chances of being contacted?
  4. How do I set myself apart from competitors for tax roles?
  5. Are there any secret strategies to get noticed for my tax skills?
  6. What do people generally not know aboud finding a job today?
  7. How can I keep my job search secret from my employer?
  8. How are people being privately exposed during job searches?
  9. What is the smartest way to find a great tax job today?
  10. What is the best way to protect my privacy during a job search?

If you are interested in being invited into this private session, please contact me at for a private invitation and access information.

What Are The Rules On Unreimbursed Employee Expenses? Freeman Law Tax Court In Brief

What Are The Rules On Unreimbursed Employee Expenses? Freeman Law Tax Court In Brief

PEEPLES v. Comm’r, Summary Op. | May 19, 2021 | Paris, J. | Docket No. 17117-17S.

Short Summary: Mr. Peeples deducted unreimbursed employee business expenses on his 2014 federal income tax return. The IRS disallowed the deductions and issued a notice of deficiency. Mr. Peeples filed a petition with the United States Tax Court challenging the proposed adjustments in the notice of deficiency.

Key Issues: Whether Mr. Peeples is entitled to deduct (1) certain unreimbursed employee business expenses and (2) tax preparation fees (under Section 162) for 2014.

Primary Holdings: No, Mr. Peeples is not entitled to deduct either because he failed to provide the Court adequate documentation or information that would have substantiated either the application of the Cohan rule for the deductions or the tax preparation expense.
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Do Wayfair Laws Need Reform To Reduce The Burden On Retailers?

Wayfair Laws

If you’re at all involved in the tax world, whether on the accounting side or as a business owner, you should be well aware of the 2018 Wayfair ruling at this point.

For an in-depth overview of South Dakota v. Wayfair (2018) and its impact on states and re tailers alike, please click here.

As a result of the Supreme Court’s decision in that case, almost every state with a general sales tax has implemented what many in the business refer to as ‘Wayfair Laws.’ More specifically, the ruling opened the door for economic nexus and marketplace facilitation legislation to be implemented across the country.

Now, nearly three years after the decision was rendered , the effects of these Wayfair laws are coming to a head and many groups are calling for reform to reduce the burden on online retailers.

Where The Complexity Comes From

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IRS Provides Guidance On Premium Assistance And Tax Credit For Continuation Health Coverage

IRS provides guidance on premium assistance and tax credit for continuation health coverage

The Internal Revenue Service today provided guidance on tax breaks under the American Rescue Plan Act of 2021 for continuation health coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA).

Notice 2021-31 provides guidance for employers, plan administrators, and health insurers regarding the new credit available to them for providing continuation health coverage to certain individuals under COBRA.

The American Rescue Plan provides a temporary 100% reduction in the premium that individuals would have to pay when they elect COBRA continuation health coverage following a reduction in hours or an involuntary termination of employment. The new law provides a corresponding tax credit for the entities that maintain group health plans, such as employers, multiemployer plans, and insurers. The 100% reduction in the premium and the credit are also available with respect to continuation coverage provided for those events under comparable State laws, sometimes referred to as “mini-COBRA.”

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Deducting Business Related Car Expenses

Deducting Business Related Car Expenses

If you’re self-employed and use your car for business, you can deduct certain business-related car expenses. There are two options for claiming deductions:

Actual Expenses. To use the actual expense method, you need to figure out the actual costs of operating the car for business use. You are allowed to deduct the business-related portion of costs related to gas, oil, repairs, tires, insurance, registration fees, licenses, and depreciation (or lease payments).

Standard Mileage Rate. To use the standard mileage deduction, multiply 56 cents (in 2021) by the number of business miles traveled during the year.

Deduct car expenses such as parking fees and tolls attributable to business use separately no matter which method you choose.

Which Method Is Better?

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Tax And Business Climate In Nebraska

Tax And Business Climate In Nebraska

This month, we take a journey out west to Nebraska, where early settlers roamed the state. It used to be nicknamed the “Tree Planter’s State,” but was changed in 1945 to the “Cornhusker State.” Husking corn was done by hand by early settlers of course (before the invention of husking machinery). The University of Nebraska athletic team is called the Cornhuskers.

Nebraska is a Midwestern U.S. State encompassing the prairies of the Great Plains, the towering dunes of the Sandhills and the panhandle’s dramatic rock formations. Lincoln, the capital and a vibrant university town, is distinguished by its soaring state capitol. The city of Omaha is home to the Durham Museum, which honors the state’s pioneering past in a converted railroad depot.

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Social Security Benefits May Be Taxable

Social Security Benefits And Taxes

Taxpayers receiving Social Security benefits may have to pay federal income tax on a portion of those benefits. Social Security benefits include monthly retirement, survivor, and disability benefits. They don’t include supplemental security income payments, which aren’t taxable.

The portion of benefits that are taxable depends on the taxpayer’s income and filing status.

To find out if their benefits are taxable, taxpayers should take half of the Social Security money they collected during the year and add it to their other income. Other income includes pensions, wages, interest, dividends, and capital gains.

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Be Safe On Social Media – Do Not Post Your Tax Information

Be Safe On Social Media - Do Not Post Your Tax Information

Waiting on your tax refund can be difficult. It can be even more so when you are unsure about the status or why there might be a delay beyond the timeframe you expected your refund. While you are checking the status of your refund or responding to any IRS requests for additional information, the Taxpayer Advocate Service (TAS) urges you to protect your personal and tax account information.

Social media timelines, forums and community groups may be a great way to connect with others and even comment publicly about something, but it’s not a great place to share your personal tax information.

Turning to social media and posting personal financial information such as tax transcripts or refund details are just examples of what you should not be doing. Also, asking personal tax details of others, puts you and them at risk for identity theft.

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IRS Offers Overview Of Tax Provisions In American Rescue Plan; Retroactive Tax Benefits

IRS Offers Overview Of Tax Provisions In American Rescue Plan; Retroactive Tax Benefits

The Internal Revenue Service yesterday provided an overview of some of the key tax provisions in the American Rescue Plan Act.

Several provisions affect the 2020 tax return people are filling out this filing season, including one exempting up to $10,200 in unemployment compensation from tax and another benefiting many people who purchased subsidized health coverage through either federal or state Health Insurance Marketplaces. In addition, the law also includes a third round of Economic Impact Payments, now going out to eligible Americans, that are generally equal to $1,400 per person for most people, as well as several other key changes for tax-year 2021.
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