Rethinking international penalty administration
Maintaining integrity in tax administration often requires the use of penalties to encourage voluntary compliance....Defining software development costs
The law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, eliminated the...Aggregation rules affecting foreign-owned companies
Multinational businesses headquartered overseas customarily conduct operations in the United States via local subsidiaries. These...Filing Your Startup’s Tax Return for the First Time
Filing a return for a startup for the first time can be overwhelming considering everything...State Sales Tax Compliance for Startups
Startups face a number of challenges from hiring qualified employees, to research and development, to...Do Startups Need Audited Financial Statements?
By law private companies are not required to undergo an annual audit of financial statements...Redetermining foreign taxes in a post-TCJA world
The foreign tax redetermination (FTR) rules under Sec. 905(c) apply to taxpayers who accrue foreign...Managing tax audits using sampling techniques
Sampling is a tool that is generally used whenever there is a list of records,...Taxation of employees’ use of corporate apartments
Taxable compensation from use of an employer-provided corporate apartment Absent an applicable exclusion, the fair...Tax fraud and bankruptcy dischargeability
The federal laws governing bankruptcy and taxation often intersect, although their makeup, effectiveness, and interpretation...Nonwillful FBAR penalties apply per report, not per account
The Supreme Court, in a 5–4 decision, held that the penalty under Section 5321 of...M&A pitfalls for deferred research expenditures
Effective for amounts paid or incurred in tax years beginning after Dec. 31, 2021, the...Archive
November 3, 2023
Maintaining integrity in tax administration often requires the use of penalties to encourage voluntary compliance. However, it is crucial that... Read more
October 31, 2023
The law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, eliminated the option to currently deduct research... Read more
October 20, 2023
Multinational businesses headquartered overseas customarily conduct operations in the United States via local subsidiaries. These U.S. companies, often structured as... Read more
October 17, 2023
Filing a return for a startup for the first time can be overwhelming considering everything else that is going on... Read more
September 25, 2023
Startups face a number of challenges from hiring qualified employees, to research and development, to marketing and market research, to... Read more
September 19, 2023
By law private companies are not required to undergo an annual audit of financial statements required of public companies, however,... Read more
August 24, 2023
The foreign tax redetermination (FTR) rules under Sec. 905(c) apply to taxpayers who accrue foreign taxes and either (1) pay... Read more
July 10, 2023
Sampling is a tool that is generally used whenever there is a list of records, also known as the population,... Read more
June 5, 2023
Taxable compensation from use of an employer-provided corporate apartment Absent an applicable exclusion, the fair market value (FMV) of any... Read more
June 5, 2023
The federal laws governing bankruptcy and taxation often intersect, although their makeup, effectiveness, and interpretation are significantly impacted by distinct... Read more