Follow-up comments on cost-sharing regulations.
The following comments were filed with the U.S. Department of the
Treasury and the Internal Revenue Service on October 20, 2006. They were
prepared under the aegis of TEI's International Tax . . .
E-filing year one: looking back and planning for the
future.
September 15 marked the one-year anniversary of the Modernized
e-File Initiative (MeF) for corporate income tax, when companies with
assets over $50 million were required to electronically file . . .
Update on IRS's whistleblower program.
This issue contains an article by Paul D. Scott on the IRS's
whistleblower program. After the article was completed, Congress passed
the Tax Relief and Health Care Act of 2006, which directly . . .
OECD updates TEI's European Chapter.(Organisation for
Economic Cooperation and Development)
Carol S. Schapira, President of TEI's European Chapter,
welcomed more than 80 members and guests to the fall 2006 chapter
meeting on October 11, 2006, at the Paris Rive Gauche Hotel. Among . . .
482 Services regulations and survey on LMSB
"environment" command TEI's attention: institute engages
in Canadian pre-budget cons
Reflecting TEI's increasingly global nature, international
issues dominated the Institute s technical activities this fall. TEI
testified on the section 482 services regulations in the United . . .
Canadian pre-budget consultations.
On October 26, 2006, Tax Executives Institute submitted a series of
recommendations in connection with the Canadian House of Commons
Standing Committee on Finance's Fall 2006 pre-budget . . .
The new proposed section 987 regulations.
On September 6, 2006, the U.S. Department of the Treasury and the
Internal Revenue Service released proposed regulations under section 987
of the Internal Revenue Code (the "2006 . . .
The economic substance doctrine: sorting through the Federal
Circuit's "we know it when we see it" ruling in
Coltec.
It is perhaps unfortunate, but the most recognizable line from a
Supreme Court opinion may be Potter Stewart's "I know it when
I see it" lament about the difficulty of defining obscenity . . .
Pittsburgh chapter's federal legislative update.(Chapter
News)
Chapter First Vice President Domenic Macioce, III, Education
Management Corporation; Chapter President Barbara Deem, H. J. Heinz Co.;
and featured speaker Cory Jacobs, partner in the firm of Blank . . .
Year-one corporate e-filing a success, but most companies
incurred additional costs: survey at TEI annual conference highlights
While the majority of large and mid-sized companies successfully
e-filed their federal tax returns for the first time in 2006, the
transition process did require many to invest additional resources . . .
Effective date of section 482 services regulations should be
delayed.
The following comments were filed with U.S. Department of Treasury
and Internal Revenue Service on October 6, 2006. The comments were
prepared under the aegis of TEI's International Tax . . .
Beware the whistleblower: will the IRS take a page out of
DOJ's playbook? (Dept. of Justice)
The U.S. Department of Justice has long relied on whistleblower
actions to safeguard the integrity of public expenditures, with
well-publicized and increasingly large recoveries the result. . . .
Another apology ... and year-end thank yous (plus an update on
whistleblowing).
This issue of The Tax Executive is late. Like its predecessor. And
their predecessors. This development has caused some dismay in my
family, which is blessed with a surfeit of journalists. My . . .
Scottsdale hosts TEI's 61st annual conference: more than 600
TEI members and guests gathered at the Westin-Kierland Hotel in
Sco
IRS Commissioner Mark W. Everson opened TEI's three-day Annual
conference on October 23, noting that the overall climate for addressing
non-compliance has improved significantly. "A balance . . .
Year end - a time to reflect, and look forward.(reviewing Tax
Executives Institute accomplishments)(President's page)
My last column was written on the eve of the Annual Conference in
Scottsdale, and there has been a whirlwind of activity affecting TEI and
tax executives since then. From the conference to three . . .
Sharing intellectual property with affiliates in China: status of
Chinese cost-sharing rules and other observations.
Cost-sharing arrangements represent a good approach to the inherent
tension of the low marginal cost of sharing innovation and the need for
arm s-length transfer pricing. Cost-sharing arrangements . . .
Tax planning for possible future events does not attract GAAR:
MIL (Investments) S.A. v. The Queen.(General Anti-Avoidance
Rule)
Introduction
Jean-Raymond Boulle is a very lucky man who became a very rich man.
In 1993, while he was a resident of Belize in Central America, (2) he
began to acquire shares of Diamond Field . . .
In remembrance of Lee Ann Davis.(In Memoriam)
Lee Ann Davis, a member of TEI's Cleveland Chapter for 15
years, died in early October. Ms. Davis joined TEI shortly after joining
Gould Electronics, rising to the position of Director of Tax. . . .
2006 IRPAC Report: the following report was submitted by Paul
Heller of the New York chapter, who was nominated by TEI to served
The IRS's Information Reporting Program Advisory Group is a
committee of private sector representatives who meet to review and make
recommendations to the IRS Commissioner about information . . .
Calendar of events.(Calendar)
Date Events
2006
October 22-25 61st Annual Conference
(Westin Kierland--Scottsdale, Arizona)
November 14-16 Financial Accounting for Tax Executives
. . .
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