Tax & Accounting Blog

Estates of Some 2011 Decedents Get More Time to Make Portability Election

Estates of Some 2011 Decedents Get More Time to Make Portability Election

The IRS has issued guidance giving certain estates of married individuals who died during the first six months of 2011 an extension of the deadline to make the portability election to pass the decedent’s unused estate and gift tax exclusion amount to the surviving spouse. Estates qualifying for and taking advantage of the extension will have … Read More

Form 8938 Guidance Issued

Form 8938 Guidance Issued

In December 2011, the IRS released the new Form 8938 used to report specified foreign financial assets. The form was released in response to the temporary regulations issued for IRC 6038D, as part of the larger crackdown on taxpayers with under reported foreign assets. The new form is filed with the taxpayer’s individual return if their specified … Read More

New York Tax Leaders Help Each Other with Data Management Issues

New York Tax Leaders Help Each Other with Data Management Issues

Some of the topics discussed at last week’s tax data management roundtable discussion included growing global operations and the need for accuracy and speed in tax processes. The event featured 40 New York tax professionals from companies in the area and many in attendance expressed that multiple systems were a challenge, especially with systems that aren’t integrated. Data can be difficult to find when it’s located … Read More

APB 23:  ETR Ally, Audit Risk or Both?

APB 23: ETR Ally, Audit Risk or Both?

What is APB 23? APB 23 (codification effort notwithstanding, old habits die hard) provides an exception to the general rule that a U.S. multinational company must provide U.S. taxes on the foreign earnings of its controlled non-U.S. affiliates. More specifically, APB 23 is the accounting rule that allows a U.S. multinational to assert that its … Read More

Maruca announces creation of International Practice Networks for Transfer Pricing

Maruca announces creation of International Practice Networks for Transfer Pricing

Two international practice networks have launched within the transfer pricing operation of the IRS. Transfer Pricing Director Samuel Maruca has announced the formation of two new International Practice Networks within the IRS focusing on in-bound and outbound income shifting in order to bring a higher level of professionalism within the service.  This is part … Read More

New Indian White Paper Focuses on Potential Tax Avoidance Through Transfer Pricing

New Indian White Paper Focuses on Potential Tax Avoidance Through Transfer Pricing

The Indian government recently released a new report, White Paper on Black Money. The report claims that more than 60% of international trade is conducted between related parties, and that the companies can exert significant influence in locating costs and revenues. Several practitioners have criticized the report as utilizing skewed information in terms … Read More