Tax & Accounting Blog

New Canadian Withholding Tax Documentation Requirements

New Canadian Withholding Tax Documentation Requirements

The Canada Revenue Agency (CRA) has changed its procedures for determining whether non-residents can claim a reduced rate of withholding tax under a tax treaty. Background Canada imposes a 25% withholding tax on certain types of Canadian source income paid to nonresidents of Canada.  Residents of countries with which Canada has a treaty may be … Read More

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IRS to Analyze Tax Credit Bond Credit Stripping and Credit Claims

Nearly $5 billion in qualified tax credit bonds were issued in 2009 and 2010, resulting in millions of dollars of bond tax credits claimed each year. In a heavily redacted report, the Treasury Inspector General for Tax Administration (TIGTA) has reported on its analysis of corporate and individual returns with claims for bond tax credits. … Read More

The “With and Without” Method for Allocating Income Tax

The “With and Without” Method for Allocating Income Tax

‘Twas the night before press release and all through the proof Nothing was open and there weren’t any goofs When all of sudden you awake with a fit You forgot intraperiod allocations and a deficiency you may get As the above cringe-inducing verse demonstrates, it is easy to think the tax provision is complete when … Read More

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Flintstones, Jetsons or Inspector Gadget? Regional Perspectives on Corporate Tax Compliance

At the American Bar Association’s “U.S. – Latin America Tax Planning Strategies” conference in Miami this week, I had the pleasure of speaking on a panel called “Managing Your Tax Compliance in Latin America – Systems, Processes, and People.”  Joined by tax professionals from Argentina, Brazil, and Mexico, we touched on trends in corporate tax … Read More

Transfer Pricing and Customs Valuations:  Will Your Adjustment Be Recognized?

Transfer Pricing and Customs Valuations: Will Your Adjustment Be Recognized?

What do you do when you need to make a transfer pricing adjustment, but the goods were delivered to the buyer in a prior tax year?  From a financial reporting and tax return perspective, the company within the local jurisdiction may or may not respect the adjustment.  But is that the end of the issue? … Read More

Announcing the 2013 ktMINE Royalty Rate Resource Guide

Announcing the 2013 ktMINE Royalty Rate Resource Guide

We are pleased to introduce ktMINE’s Royalty Rate Resource Guide 2013 Edition. This guide provides a comprehensive report on global licensing royalty rates and an analysis of value within specific industries, which can help transfer pricing and valuation analysts seek clarity when benchmarking IP transactions.. The industry insights within this guide are meant to provide … Read More