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Senior Vice President Tax – Family Office (Los Angeles, CA)

Senior VP Tax Job - Family Office ( Los Angeles, CA)

TaxConnections Executive Search Services Division has been retained to conduct a search for a Senior Vice President Tax for a family office in the Los Angeles, CA area. This very likable CEO has a global diversified portfolio of investments including private equity, real estate and media business holdings. This is a very special opportunity for a tax executive with family office expertise!

We would genuinely appreciate your taking the time to review the Senior Vice President Tax opportunity and refer this to anyone you know who may be interested in learning more.

An ideal Senior Vice President Tax candidate will be currently working in a family office environment and/or a Partner in a Big Four firm experience; real estate investment firm, investment fund, private equity or asset management.

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Director of Tax (Orange County, CA)

Director of Tax Job - Orange County, California

TaxConnections Inc. has been retained to conduct a search for a Director of Tax in Southern California/Orange County area. Our client is a 3B multinational holding company that offers an exciting and fun work environment aligned with a highly professional management team. This company offers an exciting dream job for a Head of Tax who wants to be located in Southern California.

The Tax Director will be responsible for overseeing and managing relationships with external and internal business partners to improve processes and procedures for the tax organization. The Tax Director must have the ability to identify areas of risk and tax opportunity for the company in all areas of international, federal, state, local, sales and use tax. Role involves a wide range of domestic and international tax matters including consolidated income tax provision, tax compliance and transfer pricing.

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Department of Treasury – Transfer Pricing Examination Process And Updates – Appeals Phase (Part VIII)

Transfer Pricing Examination Process, Appeals Phase

(The Transfer Pricing Examination Process was recently updated by the Department of Treasury – June 2018. TaxConnections posts this valuable eight part a series to keep you informed of these changes.)

C. Appeals Phase
As a best practice, the issue team will begin preparing the pre-Appeals presentation immediately after closing the case. Upon contact from Appeals that the case has been assigned, the issue team should:
• Request a pre-Appeals conference using Forms 3198 and 4665
• Contact the Appeals Officer and request examination’s presence at the taxpayer’s portion of the presentation
• Determine which LB&I team members should attend the pre-Appeals conference
• Determine the roles and responsibilities of the issue team members
• Hold mock presentations to prepare for the pre-conference meeting
• Hold the Appeals pre-conference meeting

Request a post-Appeals Conference and attend the meeting. The issue team should:
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Department of Treasury – Transfer Pricing Examination Process And Updates – Resolution Phase (Part VII)

Transfer Pricing Examination Process Part VII

(The Transfer Pricing Examination Process was recently updated by the Department of Treasury – June 2018. TaxConnections posts this valuable eight part a series to keep you informed of these changes.)

III. Resolution Phase
The goal of the resolution phase is to reach agreement, if possible, on the tax treatment of each issue examined and, if necessary, issue a Revenue Agent Report (RAR) to the taxpayer. Starting with the development of the issue and continuing through resolution,
early and frequent discussions with the taxpayer are crucial for a complete understanding of the respective merits of an issue.

A. Issue Presentation and Resolution
The issue team should meet with the taxpayer to discuss results of all issues prior to finalizing the NOPA and the Economist Report.

Focus taxpayer discussions on the following:
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Department Of Treasury – Transfer Pricing Examination Process And Updates (Part III)

IRS, Transfer Pricing Examination Process

(The Transfer Pricing Examination Process was recently updated by the Department of Treasury – June 2018. TaxConnections posts this valuable eight part a series to keep you informed of these changes.)

D. IRC Section 6662(e) Documentation Request
The Initial Transfer Pricing Documentation IDR (formerly known as the Mandatory Transfer Pricing IDR) is no longer required for all cases. Follow the Interim Instructions on Issuance of Mandatory Transfer Pricing IDR in LB&I Examinations. The Senior Revenue Agent/Team Coordinator and the issue team members will collaborate on the issuance of the IDR. It is important to issue the IDR early in the audit process to start working the issue as soon as possible to close the case timely. Please review IRM Exhibit 4.46.3-4 – Transfer Pricing Compliance Processes for specific language:

• Treas. Reg. Sec. 1.6662-6(d)(2)(iii) IDR includes a request for principal documents and an index for background documents
• Internal Revenue Code Section (IRC Sec.) 6662(e) and Treas. Reg. Sec. 1.6662- 6(d)(2)(iii) require that the taxpayer respond within 30 calendar days. The 30 days starts with the date of the IRC Sec. 6662(e) IDR
• The 30 day response time is defined by statute and is an exception to the new IDR and related enforcement processes as described in LB&I Directive on IDR Enforcement Process
• The issue team should use this 30 day period to perform analysis of currently available information, which may include prior tax returns and financial statements

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Department Of Treasury – Transfer Pricing Examination Process And Updates (Part II)

IRS , Transfer Pricing Examination Process Update

(The Transfer Pricing Examination Process was recently updated by the Department of Treasury – June 2018. TaxConnections posts this valuable eight part a series to keep you informed of these changes.)

C. Initial Transfer Pricing Risk Assessment

1. Review Prior Year Workpapers

Risk assessment includes the review of prior year workpapers, if applicable, to identify potential controlled transactions. The issue team should analyze prior year documents including, but not limited to:

• Initial and mid-cycle risk analysis
• Taxpayer’s transfer pricing documentation
• Revenue Agent Reports and closing agreements
• Notice of Proposed Adjustments (NOPA)
• International Examiner’s Report
• Economist’s Report
• Other specialist’s reports
• Functional analysis
• Appeals Case Memorandum (ACM)

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Department Of Treasury – Transfer Pricing Examination Process And Updates (Part I)

IRS, Transfer Pricing Examination Process Update

(The Transfer Pricing Examination Process was recently updated by the Department of Treasury – June 2018. TaxConnections posts this valuable eight part a series to keep you informed of these changes.)

The Transfer Pricing Examination Process provides a guide to best practices and processes to assist with the planning, execution and resolution of transfer pricing examinations consistent with the Large Business & International (LB&I) Examination Process (LEP), Publication 5125. This guide will be shared with taxpayers at the start of a transfer pricing examination so they understand the process and can work effectively with the examination team.

Transfer pricing examinations are factually intensive and require a thorough analysis of functions, assets, and risks along with an accurate understanding of relevant financial information. They are resource intensive for both the IRS and taxpayers. To ensure
resources are applied effectively, LB&I is using data analytics to identify issues for examination that have the most significant risk for non-compliance. In addition, teams should continually assess the merits of issues during an examination.

Our goal in a transfer pricing examination is to determine an arm’s length result under the facts and circumstances of the case. Teams should keep an open mind during an examination to new facts as they are identified. Arm’s length results are rarely a precise answer, but instead may be a range of results. If the facts of the case show that the taxpayer’s results fall within an appropriate arm’s length range, then our resources should be applied elsewhere. Likewise, teams should continually assess opportunities for issue resolution with taxpayers during the examination process.

The Transfer Pricing Examination Process provides a framework and guide for transfer pricing examinations. Every transfer pricing issue is unique, and teams should exercise their judgment on how to best apply this guide. This guide will be updated regularly
based on feedback from examiners, taxpayers, practitioners, and others.

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TaxConnections Gift: Motivational Inspirations eBook

TaxConnections, Motivational Inspirations eBook

We are inspired by the number of tax and financial executives,  and CEOs of companies all over the world who visit TaxConnections to find a tax professional and ask tax questions. TaxConnections Members receive the attention of CEOs in Asia, Australia, Brazil, Canada China, India, Greece, Japan, Mexico, Singapore, Switzerland, Netherlands, Thailand, Russia and the United Kingdom(to name a few) who visit our site to gain the advice of tax experts worldwide.

In addition, TaxConnections Executive Search Services Division has conducted more than one thousand tax executive searches over the years. One of the many things I learned from CFO clients who retained us to conduct searches for tax experts you should learn. CEOs and CFOs search for tax experts who can break tax down into a simple language they can understand; they need a strong tax coach on their management team. They also want to find a tax professional who inspires and motivates a tax team to productivity.

TaxConnections Motivational Inspirations eBook is our gift to you to help inspire a new generation of tax professionals coming into the profession.

Click To Receive TaxConnections Motivational Inspirations eBook

 

 

Senior Vice President Tax – Family Office (Los Angeles, CA)

VP Tax Job, Tax Executive Search

Our retained search client is a global private family office that actively manages a global diversified portfolio of investments (including private equity and real estate), is seeking to hire a Senior Vice President, Tax. This executive will oversee the company’s global tax function and all matters concerning tax planning and strategy. The Senior VP Tax must have strong pass-through tax experience with M&A experience a plus. This is an exciting position with a direct impact on the success of the family office business operations as a whole.

• Responsible for global tax planning and compliance; reviewing and filing of all domestic and international corporate, personal, partnership and other income and indirect tax returns; implementing and managing company’s income tax and indirect tax compliance activities

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IRS Rules: FATCA Reporting For U.S. Taxpayers

IRS, U.S. Citizens Reporting Foreign Assets, TaxConnections

The Foreign Account Tax Compliance Act (FATCA) is an important development in U.S. efforts to combat tax evasion by U.S. persons holding accounts and other financial assets offshore. The Treasury Department and the IRS continue to develop guidance concerning FATCA. For current and more in-depth information, please visit FATCA.

Under FATCA, certain U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on Form 8938, Statement of Specified Foreign Financial Assets. There are serious penalties for not reporting these financial assets (as described below). This FATCA requirement is in addition to the long-standing requirement to report foreign financial accounts on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) (formerly TD F 90-22.1).

FATCA will also require certain foreign financial institutions to report directly to the IRS information about financial accounts held by U.S. taxpayers or by foreign entities in which U.S. taxpayers hold a substantial ownership interest. The reporting institutions will include not only banks, but also other financial institutions, such as investment entities, brokers, and certain insurance companies. Some non-financial foreign entities will also have to report certain of their U.S. owners.

Therefore, if you set up a new account with a foreign financial institution, it may ask you for information about your citizenship. FATCA provides special (and lessened) reporting requirements about the U.S. account holders of certain financial institutions that do not solicit business outside their country of organization and that mainly service account holders resident within it. In order to qualify for this favorable treatment, however, the local foreign financial institution cannot discriminate by declining to open or maintain accounts for U.S. citizens who reside in the country where it is organized.

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Gift For Tax Professionals – Best Tax Jokes eBook

Best Tax Jokes eBook, TaxConnections

We know you will enjoy one of the most popular eBooks we provide to our tax professional members. In fact, TaxConnections members have written or provided many of the jokes in this eBook. With more than 111 tax jokes on a wide range of topics, we know you will have a few laughs with your family, friends and clients.

Tax professionals are a lot of fun and have many stories to share. We encourage you to send us your favorite tax jokes and we will include them in future editions submitted by you to promote your services.

Request – TaxConnections Best Tax Jokes eBook

https://www.taxconnections.com/best-tax-jokes-and-quotes

 

Tax Professionals – Question Of The Week

Each week TaxConnections posts a question from one of our visitors. We encourage our members to provide their insight and comments:
Canadian resident looking to enter into some sort of partnership with US citizen (LLC or similar). What is the best arrangement? I’ve read on this forum that as Canadian citizen, owning part of a US LLC may not be the best. If we want to share equity and management of the entity, what is best? Is LLP a better option, or some other? Many thanks.
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