Tag Archive for Corporate

Tax Implications Of Declaring A Management Bonus At Year End

Grant Gilmour

If your corporation has had a profitable year and your corporate year end is July or later in the calendar year, you may wish to declare a management bonus to defer some of the taxes to the next year, or to reduce income to a level of corporate tax you are comfortable with. The small business tax rate limit, for example.

Read more

Internships A to Z


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

Director of Company Cleared In $200M Corporate Tax Fraud Charges

Ronald Marini picture27

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

Attention! Corporate Multinational Tax Departments – The Tax Provision (ASC 740/FAS 109)

Shamen Dugger

Corporate Multinational Tax Departments


Gather in your conference rooms or at your desks to watch this presentation from Shamen Dugger at TaxConnections Internet Tax Summit on Tuesday, September 22, 2015 at 8:00AM (PST).  Learn from this tax expert about Tax Provision (ASC 740/FAS 109).

Introducing Tax Expert:                      (See Video Below)
Shamen Dugger, McGladrey LLP, San Francisco and San Jose, CA


Read more

Canada-US Cross-Border Tax Issues When Winding-Up a Subsidiary

TaxConnections Picture - Keys - square

Canadian corporations form US Subsidiaries, and US Corporations form Canadian Subsidiaries, all the time.

What are the cross-border tax implications when those subsidiaries are wound-up? This article will provide an overview of those implications.

Winding-up a US Subsidiary (“USco”) of a Canadian Corporation (“Canco”)

For US tax purposes, proceeds received on the wind-up of USco are generally not treated as a dividend, and hence no U.S. withholding tax should apply.

Rather, such amounts would generally represent proceeds from the shares which should Read more

The Commerce Clause – Due Process and Cross Border Taxation

TaxConnections Picture - Gavel and Flag - square

Cross border taxation risks of international enterprise incorporates two basic themes, one of which is the interpretation of the United States Commerce Clause and the Due Process distinction from jurisdictional analysis. It is one of the two basic aspects that govern the authority of a source and resident country or state to tax international commerce.

In the electronic commerce world the courts have embraced an evolution of Due Process requisite of jurisdiction and of commerce. That analysis for both turns upon the judicial case law evolution that focuses on the contact with the state or country that imposes taxation from their border. Read more

Introduction To Section 482 And International Financial Centers

Profit, Loss, Risks Dice Showing Incomes

As an introduction to International Financial Centers and the pricing concepts between structures of entities, an integration of international law principles and taxation concepts is desirable. This is the essence and difficulty of understanding Financial Centers Offshore. It requires a melding of international financial law, international civil and criminal law, and international taxation rules. It is the bifurcation of these disciplines that makes International Financial Centers so elusive.

The foundation to a discussion of entity structure concepts is melding the taxation rules peculiar to foreign corporate entities; controlled entity rules, source of income Read more

Divisive Foreign Corporate Reorganizations

TaxConnections Picture - Corporate Buildings

Corporate reorganizations are valued tools to the practitioner. They provide the opportunity to defer taxable events by virtue of non-recognition treatment. They are characterized as acquisitive, reformative, and divisive transactions. Currently they are relevant as timely transactions as publicly traded security prices have soared while revenue growth has slowed. Companies can grow by shrinking, selling off under performing assets and putting the cash to work. (See Jack Hough, Buy the Asset Sellers, Barron’s Magazine, Saturday, December 7, 2013)

In a previous writing (Tax Connections/Foreign Corporate Acquisitive Reorganizations) the Read more