print Tax: Publications
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International Executive Services
2010 An extraordinary amount of the corporate value of a multinational corporation is contained in human capital. The ability to relocate key employees quickly from one location... more | view as PDF |
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Taxpayer Victory in 'Deloitte' Breathes Fresh Air in Continuing Battle Over Tax Accrual Work Papers
August 3, 2010 The U.S. Court of Appeals for the District of Columbia Circuit recently found in United States v. Deloitte that documents related to a company’s LLP tax accrual work... more | view as PDF |
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Caution: New IRS Procedures Allow Whistleblowers to Gain Access to a Taxpayer’s Confidential Information
June 2010 The Internal Revenue Service (“IRS”) has released new and updated sections of the Internal Revenue Manual (“I.R.M.”) that explain how the... more |
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June 30, 2010 Deadline Approaching for Certain U.S. Persons Required to File Reports Relating to Foreign Bank Accounts
June 15, 2010 Increased Enforcement Efforts in the International Arena The Internal Revenue Service (“IRS”) has placed offshore tax abuses, along with various other... more |
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Proposed Legislation Would Provide Tax Incentives for Renewable Energy Sector
May 18, 2010 On May 12, Senators John Kerry (D-MA) and Joe Lieberman (I-CT) introduced the “American Power Act (the “APA”), a broad-ranging bill that seeks to build a... more |
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The New Tax Credit/Grant for Small Companies: What You Need to Know Right Now
May 4, 2010 The new healthcare reform lag sets aside $1 billion for tax credits or grants for small biotech companies (250 employees or less) for certain research projects. The... more | view as PDF | view as PDF | view as PDF |
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Fulbright Forum - The Latest Word on the Use of Independent Contractors: Tax, ERISA, and Labor & Employment Law Issues
May 4, 2010 Is the worker an independent contractor or an employee? That question interests the Internal Revenue Service, the Department of Labor, the Equal Employment Opportunity... more | view as PDF |
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The IRS Takes a Controversial Position on Uncertain Tax Positions
April–May 2010 On January 26, 2010, the IRS issued Announcement 2010-9, which bears the title “Uncertain Tax Positions Policy of Restraint.”1 Immediately controversial, the... more | view as PDF |
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New Tax Credit for Small Biotechs — Therapeutic Discovery Project Credit and Cash Grants
April 2010 The Patient Protection and Affordable Care Act (the “Act”), enacted on March 23, 2010, establishes a new 50 percent investment tax credit for certain investments... more |
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IRS Releases Draft Schedule and Instructions for Reporting Uncertain Tax Positions
April 23, 2010 In a prior Fulbright Briefing ( IRS Announces New Broad Disclosure Requirements for Uncertain Tax Positions ), we described the January 26, 2010 Internal Revenue Service... more |
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HIRE Act: Congress Targets Foreign Institutions, Foreign Financial Assets and Foreign Trusts
April 16, 2010 On March 18, 2010, President Obama signed the Hiring Incentives to Restore Employment (“HIRE”) Act (H.R. 2847) (the “Act”), which imposes additional... more |
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IRS Help for Struggling Taxpayers Contrasts With Enforcement Push
April 5, 2010 Treasury auditors have praised IRS efforts to assist economically distressed taxpayers even as return preparers report that the agency’s enforcement activities are... more | view as PDF |
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HIRE Act Imposes New Reporting and Withholding Requirements on Foreign Financial Institutions
April 1, 2010 On March 18, 2010, President Obama signed into law the Hiring Incentives to Restore Employment (“HIRE”) Act (H.R. 2847) (the “Act”), which contains... more |
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Clarification of the Economic Substance Doctrine May Have Beneficial Side Effects for Taxpayers
March 30, 2010 On March 30, 2010, the President signed into law H.R. 4872, the Health Care and Education Reconciliation Act of 2010 (the “Act”), which is the second and final... more |
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All That Glitters Is Not Gold...Entering Into and Enforcing Charitable Pledges in Texas
Winter/Spring 2010 Over his life, infamous oil executive J. Howard Marshall, pledged millions of dollars to his alma matter, Haverford College. In response to Marshall’s generous pledges... more | view as PDF |
