Corporate Tax Reporting Draws GAO Scrutiny

Wall Street Journal, Aug 13, 2008

Corporate Tax Reporting Draws GAO Scrutiny

Wall Street Journal, Aug 13, 2008

At least 23% of large U.S. corporations don't pay federal income taxes in any given year, according to a report by the investigative arm of Congress.

FIN 48 Noncompliance

Compliance Week, Jul 29, 2008

FIN 48 Noncompliance

Compliance Week, Jul 29, 2008

More than one quarter of large public companies are not meeting the disclosure requirements for tax reserves required under the controversial, tell-all accounting rule Financial Interpretation No. 48, Accounting for Uncertainty in Income Taxes.

How the Tax Executives Should Approach IFRS

Compliance Week, Jul 22, 2008

How the Tax Executives Should Approach IFRS

Compliance Week, Jul 22, 2008

As a U.S. transition to international accounting standards appears more and more inevitable, corporate tax departments need to get a seat at the table to assure they're included in the monumental planning process that is beginning to unfold.

European Groups Operating in the US: Managing Transfer Pricing Risks

New European Economy, Jul 14, 2008

European Groups Operating in the US: Managing Transfer Pricing Risks

New European Economy, Jul 14, 2008

The increasing number of cross-border transactions combined with the greater complexity of group structures can lead to ever-greater risk in tax planning and, in particular, in transfer pricing. European- based groups of companies doing business in the United States can face significant challenges partly because of the need to deal with two or more tax authorities whose perspective on particular transactions may be very different.

Korb Says FTC Generator Transactions Already in Pipeline, Designated for Litigation

Daily Tax Report, Jul 11, 2008

Korb Says FTC Generator Transactions Already in Pipeline, Designated for Litigation

Daily Tax Report, Jul 11, 2008

As the Bush administration winds down and the agency begins what Internal Revenue Service Chief Counsel Donald Korb called "the sprint to the end," the chief counsel outlined some issues he said are likely to define the tax landscape going forward. Among them are a continuation of the increased focus on transparency in examinations and litigation and on IRS's joint efforts with other taxing authorities to look at cross-border issues.

Taxation and Representation

CFO.COM, Jul 3, 2008

Taxation and Representation

CFO.COM, Jul 3, 2008

In an effort to speed the convergence of American and international accounting, rulemakers at the Financial Accounting Standards Board are considering making no further tweaks to U.S. rules for tax accounting. Instead, they may simply toss out those rules in favor of the international financial reporting standard, which rulemakers in London are also modifying in an ongoing effort to reduce differences between the two systems.

Tax Code, Global Accounting Rules Seen Clashing

Reuters, Jun 16, 2008

Tax Code, Global Accounting Rules Seen Clashing

Reuters, Jun 16, 2008

Regulators at the U.S. Securities and Exchange Commission are currently crafting a road map that would set milestones and targets for U.S. companies to drop U.S. GAAP and join more than 100 other companies using International Financial Reporting Standards (IFRS). But, the U.S. tax code and other basic facts of U.S. corporate life would need revising to enable U.S. companies to meet these international rules.

A Meeting of Minds - Resolving Transfer Pricing Controversies

KPMG International, Aug 5, 2008

A Meeting of Minds - Resolving Transfer Pricing Controversies

KPMG International, Aug 5, 2008

Tax authorities looking to enforce transfer pricing regulations are increasing the range of company transactions they will use as a trigger for more detailed investigations, according to insights provided by advisors from KPMG’s Global Transfer Pricing Services practice.

Changes in the Climate of Tax Administration in the U.K. and the OECD

TGI Webcast Executive Summary, May 8, 2008

Changes in the Climate of Tax Administration in the U.K. and the OECD

TGI Webcast Executive Summary, May 8, 2008

The Tax Governance Institute (TGI) recently hosted a live video Webcast on the changing climate of tax administration in the United Kingdom and the Organisation for Economic Co-operation and Development (OECD). This executive summary highlights the discussion of the tripartite relationship between revenue bodies, taxpayers, and tax intermediaries, and how this relationship may influence the revenue bodies' ability to assess the tax risk presented by the taxpayers.

IFRS is Coming, What Does This Mean for Tax?

Washington National Tax, KPMG LLP, Apr 11, 2008

IFRS is Coming, What Does This Mean for Tax?

Washington National Tax, KPMG LLP, Apr 11, 2008

Many companies are in the early stages of considering what impact the transition to International Financial Reporting Standards (“IFRS”) from U.S. Generally Accepted Accounting Principles (“U.S. GAAP”) will have on financial reporting; however, are they also thinking about the impact it will have on tax reporting?

Changes in Tax Reserves in Anticipation of FIN 48

Social Science Research Network (SSRN), Mar 18, 2008

Changes in Tax Reserves in Anticipation of FIN 48

Social Science Research Network (SSRN), Mar 18, 2008

FIN 48, Accounting for Uncertainty in Income Taxes, introduces new disclosure and computational requirements that reduce discretion in estimating tax reserves. FIN 48’s adoption rule requires firms to record cumulative effect adjustments in stockholders’ equity rather than through earnings. The author's predict that over-reserved firms will decrease their tax reserves in advance of adoption because such releases will enhance earnings and potentially decrease visibility to the IRS.

FIN 48 and Tax Compliance

Social Science Research Network (SSRN), Mar 5, 2008

FIN 48 and Tax Compliance

Social Science Research Network (SSRN), Mar 5, 2008

The authors developed a model to examine the effects of Financial Accounting Standards Board (FASB) Interpretation No. 48, Accounting for Uncertainty in Income Taxes (FIN 48) on the strategic interaction between publicly-traded corporate taxpayers and the government. Their model demonstrates that the economic effects of FIN 48 include: higher expected payoffs to some taxpayers that claim uncertain tax benefits; a disclosed liability that may understate the expected tax liability; and continued claims of uncertain tax benefits by taxpayers whose circumstances only weakly support their position. Their findings contradict conjectures in the popular press.

Implications of the New, Heightened Tax Return Preparer Penalties

TGI Webcast Executive Summary, Feb 21, 2008

Implications of the New, Heightened Tax Return Preparer Penalties

TGI Webcast Executive Summary, Feb 21, 2008

The Tax Governance Institute (TGI) recently hosted a live videocast panel discussion regarding the implications of the new, heightened tax return preparer standards. The panel included an attorney-advisor in the Office of Tax Policy, U.S. Department of Treasury, and one of the principal authors of the guidance; a former Treasury associate legislative counsel; and a former deputy commissioner of the Internal Revenue Service.

FASB Defers Interpretation 48 for Nonpublic Entities

KPMG Defining Issues, Jan 25, 2008

FASB Defers Interpretation 48 for Nonpublic Entities

KPMG Defining Issues, Jan 25, 2008

Defining Issues 08-5 discusses the FASB’s decision to permit nonpublic entities to defer applying FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes, until they prepare their annual financial statements for years beginning after December 15, 2007, unless they have already issued a complete set of annual financial statements that fully reflect the Interpretation’s requirements or are nonpublic subsidiaries of public entities that report in U.S. GAAP. The FSP that will incorporate these decisions is expected to be issued soon.

IFRS: Tax Considerations when Converting from U.S. GAAP