Tax & Accounting Blog

The Interplay Between the Internal Revenue Code’s Section 163(j) and Transfer Pricing

With recent news of limits on intercompany debt in Australia, China, New Zealand, and the UK, many U.S. affiliates in these countries incurred substantial debt. While U.S. tax law does not place formal limits on the extent of debt versus equity financing, section 482 requires that the interest rate on intercompany debt … Read More

Delaware Proposes Regulation for Certain Securities and Related Property

Delaware Proposes Regulation for Certain Securities and Related Property

The securities proposed regulation defines “Securities and Related Property” as property that consists of: Intangible ownership interests in corporations, whether or not represented by a stock certificate, bonds, and other securities; Dividends, cash, stock and other distributions made (or attempted to be made) by issuers of securities in respect of … Read More

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Penalties for Failure to Comply with NRA Withholding and 1042-S Information Reporting: Part 2 – A Penalty for Late Deposit

The IRS prescribes when deposits of NRA withholding are required in IRS Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities. A payer who fails to make a required deposit of withheld taxes within the time prescribed is liable for a penalty on the underpayment (i.e., the excess of the … Read More

We’re Listening: Modern and Common User Interface

We’re Listening: Modern and Common User Interface

You asked… we’re delivering. At the 2011 ONESOURCE User Conference, we heard feedback from our 1500+ clients in attendance via a new program launched so that we could hear everything our customers care about most. In this series, I’ll share with you how we’re implementing customer … Read More