Tax publications

Featured publications


IFRS: The right move toward convergence: What IFRS will mean to US tax executives
This paper can assist you in understanding the related tax considerations and discussing IFRS with other functional leaders within your company.


Continuing developments in the taxation of insurance companies
The annual monographs provide overviews of developments affecting the taxation of insurance companies. We have selected for specific review those developments of major significance to the insurance industry.


State and local tax trends affecting business in 2008: Looking back, looking ahead is intended to help companies work through the 2007 state and local tax changes with efficiency and effectiveness. Our intent is not to cover all of the year's changes or to provide specific information on how you should deal with them. However, we believe you will find this overview of selected 2007 changes valuable as you incorporate them into your own business decisions.


Exempt organizations


IRS Form 990 redesign comments
On June 14, 2007, the IRS released for public comment a discussion draft of a redesigned Form 990 (Return of Organization Exempt From Income Tax), which includes significant revisions to the form. PricewaterhouseCoopers' exempt organizations tax services group submitted comments to the IRS based on our experience and judgment as practitioners.


FIN 48

Determining uncertain tax positions in China
For companies operating in China, tax planning is complex related to Uncertain Tax Positions ("UTPs") and compliance with FASB FIN 48 requirements.

Determining uncertain tax positions under FIN 48 for operations in Mexico
Companies are beginning to evaluate the US Financial Accounting Standards Board (FASB) Interpretation Number 48 (FIN 48) for their Mexican operations. FIN 48 will have a significant impact for US companies with operations in Mexico, Mexican companies listed on US exchanges and those companies preparing information under Generally Accepted Accounting Principles (GAAP) in the US.

FIN 48 international operations
On January 17, 2007, the Financial Accounting Standards Board (FASB) decided not to delay the effective date of FIN 48. As a result, calendar year-end companies will need to adopt the provisions of FIN 48 as of January 1, 2007.

Lifting the fog: Accounting for uncertainty in income taxes
This document discusses the Interpretation and highlights its most significant consequences for identifying, recognizing, and measuring uncertain tax positions. It also describes the new disclosures that are likely to increase the spotlight on uncertain tax positions, the accounting for changes in subsequent periods, the treatment of interest and penalties, balance sheet classifications, and internal controls. Further, it offers insights and considerations for effectively navigating this new guidance.

Thinking beyond uncertain tax positions
This whitepaper provides an overview of understanding the potential impact of interest computation and penalties related to FIN 48.


Health policy economics


The factors fueling rising healthcare costs
This report prepared by PricewaterhouseCoopers on behalf of America's Health Insurance Plans (AHIP), this 2006 report examines the causes of rising health care costs and analyzes how health insurance premium dollars are being spent.

Pharmacy benefit management savings in Medicare and the commercial marketplace and the cost of proposed PBM legislation, 2008-2017
The Pharmaceutical Care Management Association (PCMA) retained PricewaterhouseCoopers (PwC) to estimate the value of pharmacy benefit management as well as the potential impact of enactment of proposed legislation that would restrict pharmacy benefit management (PBM) activities for consumers, private employers, health plans, unions, and state and federal governments.

President Bush's second term: Prescribing private solutions for the nation's healthcare problems
PricewaterhouseCoopers' Health research institute (HRI) developed a comprehensive 360 degree view of President Bush's health plan, the challenges and opportunities for industry, and an analysis on the likelihood of implementation.

A PricewaterhouseCoopers' report shows the impact of Medicare prescription drug coverage on low-income beneficiaries
This report for The Alliance to Improve Medicare shows the impact of the new Medicare Prescription Drug, Improvement and Modernization Act of 2003 (MMA) will be most dramatic for Medicare beneficiaries with high out-of-pocket expenses who do not currently have prescription drug coverage. For example, a beneficiary with prescription drug spending of $10,000 and no coverage in the absence of the MMA would see out-of-pocket expenses fall by $6,155 or 62%, under the MMA.

Significance of the coverage gap under Medicare Part D
Prepared by PricewaterhouseCoopers on behalf of the Healthcare Leadership Council, this brief analyzes the drug spending patterns and insurance coverage characteristics of Medicare beneficiaries to assess the impact of the coverage gap of Medicare Part D on Medicare beneficiaries.


Human resources


2008 Guide to tax and financial planning
The guide is designed to help employee benefit plan sponsors, plan administrators, plan trustees, attorneys and accountants comply with the reporting and disclosure requirements of the Employment Retiree Income Security Act of 1974 (ERISA) and the Internal Revenue Code.

2008 Guide to tax and financial planning
The book provides advice and tips on how to sort through the current tax rules and help plan future tax stategies based on the most recent changes such as tax rate changes, new deductions and credits, and often overlooked ways to save tax dollars.

2007 Global equity incentives survey
Harnessing the reward: Equity compensation evolving role in total compensation

This year's survey documents emerging best practices related to the design, accounting, tax planning, global coordination, and process and administration aspects of equity compensation. Additionally, this year’s survey asks new questions related to corporate controls, financial reporting, corporate tax, valuation, performance and market based metrics, customization of global plans to local markets and demographic groups, and total rewards.

HR innovation: Winter 2007 – In this issue of HR innovation, we address some key issues to provide HR and corporate decision makers with innovative approaches on how to help their companies gain competitive advantage in this changing marketplace.

HRS insights
US human resource services newsletter on the latest HR issues companies encounter. Usually address new legislative and regulatory updates, as well as developments affecting the accounting for employee benefits and compensation. Select categories of interest include: Compensation, healthcare and reetirement.

International assignment perspectives: Special alerts
International assignment perspectives is a collection of thought leadership articles that explore current issues around mobility requiring the attention of today's HR leaders and tax directors.

Key trends in human capital: A global perspective
Saratoga presents "Key trends in human capital: A global perspective"—our analysis of key HR trends facing the United States and European business. The analysis encompasses data from over 10,000 organisations across a range of industries. It reveals the important human capital issues facing global business, and measures the total value of human capital and return on investment.

Managing tomorrow's people: The future of work to 2020
PwC's human resource services practice's report on the future of work to 2020 and how organisations will face the challenges of a changing workforce.

The right peer group for the right pay plan
Guiding principles for formulating a peer set that will withstand heightened scrutiny and promote rational pay decision making.

US human capital effectiveness report 2007/2008
This executive summary provides analysis on trends PwC Saratoga has uncovered through it's annual human capital survey and is organized around the following key themes: Workforce improvements are stabilizing; skilled labor volatility; managing labor costs; and managing HR investments.


International assignment services


Global watch
This newsletter provides important global news and developments. The newsleter addresses current issues related to income and social tax, legislation, changes in employment rules, treaties, rulings, etc. Each of these is categorized by country or territory to allow you to subscribe to the territories of greatest interest to you and your organization.


International tax


Asia-Pacific tax newsalert
This newsletter provides periodic updates that affect any company operating in the Asia-Pacific theater.

Customs international trade newsalert
This newletter provides periodic news relating to customs taxation.

Financing international operations
The US Treasury and IRS issued proposed regulations under Code Sec. 987 of the Internal Revenue Code providing rules for the translation of income earned through a branch or qualified business unit (QBU) that conducts business in a foreign currency. The "2006 Proposed Regulations" would adopt a completely different method (the so-called "foreign exchange exposure pool method" for translating branch income than the "profit and loss" method contained in the 1991 Proposed Regulations for which the 2006 regulations replace.

International tax perspectives
This publication is a compilation of thought leadership pieces which address a cross-section of international tax issues and developments.

Shifting the balance: The evolution of indirect taxes
Our new publication, offers an insight into the growth of indirect taxes around the world, drawing on data gathered from across our global indirect tax network.

European tax newsalert
This newletter provides periodic updates that affect any company operating in Europe, the Middle East and Africa.

Trade intelligence: Americas
This bi-monthly publication coveri current issues related to customs, international trade, and indirect taxes in the Americas and beyond.

This month in M&A
This newsletter provides recent news pertinent to the mergers & acquisition tax issues that include the latest Treasury regulations; IRS Rev. Procs. and Regs.; and court decisions.

US inbound newsalert
This newsletter provides periodic news on tax and legislative issues related to companies headquartered outside the US doing business in the US.

US outbound newsalert
Thjis newsletter provides periodic news on US legislation affecting companies with international operations.

US tax treaty developments
This newsletter series covers developments related to the interpretation and application of US income tax treaties, including international developments that may impact US tax treaty interpretation or policy.

VAT newsalert
This newsletter provides a periodic newsletters relating to customs taxation and VAT.

Worldwide tax summaries
This whitepaper provides an up-to-date overview of the corporate and individual tax rates and rules in operation in over 100 countries.


State and local tax


Capitalizing on your negotiated incentives
This article provides several strategies that corporate site selectors can use to ensure that the amount of incentive assistance offered by state and local jurisdictions is actually received by the company.

myStateTaxOffice (mySTO)
This weekly publication provides news, analysis, and insights on state and local taxes.


Section 199


Preparing for a Section 199 examination: Auditing pitfalls and approaches
This article will consider various IRS initiatives implemented to address Code Sec. 199 and, in addition, will highlight specific areas of complexity and the documentation that may be required to substantiate a taxpayer's Code Sec. 199 deduction.


Tax accounting


IFRS: The right move toward convergence

Guide to accounting for income taxes 2007
This publication is intended to clarify the fundamental requirements involved in the accounting for income taxes and to highlight key points that should be considered before transactions are undertaken.


Transfer pricing


Chinese transfer pricing implications: Distribution of recently introduced products
This article discusses some of the transfer pricing issues that multinational companies need to consider when setting up FICEs to distribute the products sourced from their domestic or overseas affiliates, particularly the products that are newly introduced into the Chinese market.

FSTP perspectives
This financial services transfer pricing newsletter provides bi-monthly updates that offer insights into trends and developments, tax authority approaches, and current issues in financial services transfer pricing.

Pricing knowledge network
This newslettter provides alerts and analysis of major inter-company pricing issues and related developments from around the world.

Transfer pricing in the context of a PE: The OECD view
The report reflects the current view of the OECD's Committee on Fiscal Affairs with respect to attributing profits to a permanent establishment (PE).

Transfer pricing global perspectives memo
FIN 48: Uncertain tax positions associated with transfer pricing – Some frequently asked questions from a global perspective.

Transfer pricing perspectives
This publication addresses many hot topics in transfer pricing, including the proposed cost-sharing regulations, the new temporary and proposed services regulations, transfer pricing controversy in Mexico, the application of the profit-split method in the financial services industry, and interstate transfer pricing.

Transfer pricing regulations affect retail and consumer multinationals
This QuickBrief summarizes recent changes to transfer pricing regulations that will affect retail and consumer companies in several important areas including tax compliance, financial reporting and administrative burden.


Washington national tax services (WNTS)


The corporate tax conundrum
This background paper describes the taxation of corporate and noncorporate businesses in the United States, compares the US corporate tax system with that of its major trading partners, and describes the major economic distortions caused by the US rules for taxing income from capital.

Don't go it alone! The IRS collection process
The article examines the various steps of the IRS collection process and provides guidance for taxpayers and their advisors.

FIN 48 and tax accrual workpapers: A new LMSB approach?
The Washington national tax practice provides analysis of two IRS documents issued in 2007 that provide insights into how the IRS will use existing FIN 48 disclosures and how the IRS may be re-evaluating its long-standing "policy of restraint" on tax accrual workpapers.

Final regulations modify reportable transaction disclosure rules
This publication summarizes modifications made to the prior Section 6011 regulations regarding the disclosure of reportable transactions, including disclosures that taxpayers may be considering for tax returns expected to be filed.

Impact of the exchange of tax information between the IRS and foreign tax authorities
This article provides the background behind exchange of information requests, describes the exchange process, and discusses how taxpayers can address an exchange of information request.

Increased IRS audits of foreign corporations: US multinationals with controlled foreign corporations also targeted
This publication emphasizes auditing of US Income tax returns of foreign corporations (Forms 1120-F). The emphasis applies to both "protective" and regular Forms 1120-F.

IRS service team hot topics
This newsletter provides important information involving the IRS—what we are seeing, and what you as a tax professional want to know. The hot topics alerts make it easy for you to spot issues relevant to your company.

Tax policy perspectives
Tax policy perspectives, from Washington national tax services, is a compilation of articles that shares insights in response to pressing tax policy developments that extend well beyond the tax function.

Featured publications


IFRS: The right move toward convergence: What IFRS will mean to US tax executives
This paper can assist you in understanding the related tax considerations and discussing IFRS with other functional leaders within your company.


Continuing developments in the taxation of insurance companies
The annual monographs provide overviews of developments affecting the taxation of insurance companies. We have selected for specific review those developments of major significance to the insurance industry.


State and local tax trends affecting business in 2008: Looking back, looking ahead is intended to help companies work through the 2007 state and local tax changes with efficiency and effectiveness. Our intent is not to cover all of the year's changes or to provide specific information on how you should deal with them. However, we believe you will find this overview of selected 2007 changes valuable as you incorporate them into your own business decisions.


Insurance


Insurance tax bulletins   
Subscribe to receive insurance tax bulletins
One page summaries of insurance tax developments affecting insurance companies and their products.

Americas insurance digest
This publication is dedicated to providing thought-provoking insights into some of the key strategic issues facing the insurance industry in the Americas.

Continuing developments in the taxation of insurance companies
The annual monographs provide overviews of developments affecting the taxation of insurance companies. We have selected for specific review those developments of major significance to the insurance industry.

Closing agreements and the federal excise tax
This bulletin examines why many foreign (i.e. non-US) insurance and reinsurance companies, who write direct business in the US, or reinsure US risk, are entering into closing agreements with the Internal Revenue Service (IRS) in order to secure an exemption from federal excise tax (FET) on their US lines of business, a benefit granted by certain US income tax treaties.

Focus on growth
The 11th report in our global financial services series. The briefing, written in cooperation with the economist intelligence unit, focuses on the strategic issues around the growth agenda.

The future of financial services
Piecing the jigsaw is a paper focusing on the future of the financial services industry over the next three years and considers the drivers, risks and opportunities, as well as the impact and responses for existing and potential players in the industry.

Innovative financing: life insurance securitization
This paper (the second in the focus on restructuring series) discusses these opportunities covering the range of actuarial, regulatory and other financial matters as well as some of the potential pitfalls, including what can be learned from recent transactions.

Standing up to scrutiny
This paper examines insurance analysts' perspectives on the latest developments in financial reporting and their views on the way forward.

Treatment of insurance companies under dual consolidated loss regulations
Recently issued final regulations that provide guidance on dual consolidated losses (DCLs) clarify the rules for insurance companies that make Section 953(d) elections, but they also raise new concerns about the treatment of "domesticated" insurance companies. Read PricewaterhouseCoopers' analysis of the regulations.


Investment management


Alternative fund investments in Latin America
The Latin American alternative investment funds segment (which includes hedge funds, private equity funds, and real estate funds) has begun to flourish. Many new funds are being formed in the region, with Brazil and Argentina serving as hosts in many cases. While emerging market funds around the world are, on average, four times larger than Latin American funds, the growth of the alternative fund industry in Latin America has been outstanding.

Recent trends for alternative fund investments in China
US fund managers can now explore a wide spectrum of Chinese opportunities covering capital market portfolio investment, private equity, distressed debts, real estate and other high-yield investment assets. However, the Chinese investment and tax environment is extremely challenging because of constantly changing regulations, ambiguous interpretation of tax policies and inconsistent enforcement practices.

Pharmaceuticals


Pharma and life sciences tax news
This newsletter provides technical and regulatory developments relevant to the pharmaceutical and biotechnology sectors.

Real estate


IRS issues notice regarding REIT distributions to foreign persons
On June 13, 2007, the United States Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued Notice 2007-55 which addresses the US federal income tax treatment of distributions from REITs to foreign governments.

Real estate tax update
This publication addresses current real estate issues.

REITS and FIRPTA
On May 17, 2006, President Bush signed into law the Tax Increase Prevention and Reconciliation Act of 2005 (PL 109-222) (TIPRA). TIPRA included three provisions affecting foreign investors in REITS: The first codifies the 35% withholding rule found in the Treasury regulations; the second adds a wash sale rule; and the third provides for a look-through rule on tiered REIT structures. This article first appeared in Real Estate Finance.

The sun also sets: Making the most of TIPRA’s changes to FIRPTA while they last
This article will describe some of the changes in the law and their expected sunsets, discuss their application to some typical situations, and suggest internal controls to help with compliance.

Treasury issues regulation on amortization of loan costs
PwC tax services examines the the US Department of Treasury adopted Regulation Section 1.446-5, which addresses the treatment of debt issuance costs.


Technology


2007 technology sector tax benchmarking study
The 2007 study comprises 64 technology companies. The companies involve four segments: Software & services; Internet; Computers & networking; and Semiconductors The data is compiled from publicly available financial statements ending on or in the period March 2004 to December 2006.






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Juliet Garavelli
US tax thought leadership
Tel: +1 (646) 471 4297
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