Tax publications

Service offering publications
Industry sector publications


Featured publications


IFRS for SMEs: A less taxing standard? IFRS for SMEs: A less taxing standard?
This article highlights key provisions of the income tax accounting guidance contained in the IFRS standard for small and medium-sized entities. The article provides comparison to existing IFRS, the IASB's proposed exposure draft on income taxes and US GAAP, as well as our observations of the potential impact of these provisions within IFRS for SMEs.
Measuring the impact of key international tax proposals: The importance of modeling Measuring the impact of key international tax proposals: The importance of modeling
Modeling can help companies understand the potential impact of the Administration’s key international tax proposals. Once the modeling has been completed, a company can consider how its tax liability could change — both on a short-term (cash) basis and a longer-term (effective tax rate) basis.
Global mobility in a downturn: Managing through and emerging stronger Global mobility in a downturn: Managing through and emerging stronger.
Today, every facet of a business is impacted by the burgeoning global economy, and naturally this has an impact on global mobility programs. In this document, PricewaterhouseCoopers' International Assignment Services practice explores best approaches to managing global mobility programs in the current economic downturn as a means to emerge stronger on the heels of an upturn.

Cash tax savings

10Minutes on bolstering corporate liquidity
10Minutes on bolstering corporate liquidity discusses how companies today face an environment where credit is still scarce and cash is king. While companies can employ short-term cash management and tax strategies to provide liquidity relief today, they must also develop a more long-term approach to liquidity planning to mange through a re-pricing of credit risk and an extended downturn.


FIN 48

A comparison of FIN 48 and the tax penalty standard
PwC overview of the FIN 48's more likely than not (MTLN) standard on whether a position taken, or expected to be taken, in a tax return is more likely than not to be sustained.

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

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.

Healthcare policy in an Obama administration: Delivering on the promise of universal coverage
This report examines the challenges the Obama administration faces, explains how these reforms may be enacted, the potential impact for employers as well as those in the health industry and provides five ideas for making health care more affordable.


Human resources

2008 ERISA guide to reporting & disclosure
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.

2007 Global equity incentives survey
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
HR innovation is a collection of thought leadership articles that explore current issues requiring the attention of today’s HR professionals.

International assignment perspectives: Volume 3
This assemblage of articles prepared by PwC's international assignment services practice, addresses the important considerations when contemplating making changes to your global mobility program covering such topics as expanding into new markets, managing mobility in a downturn, corporate acquisition considerations, data privacy concerns, equity-based compensation, among others.

International assignment perspective: Volume 2
This compilation from PwC's international assignment services practice shares fresh perspectives on a number of topics affecting multinational companies, including tax equalization, multi-state reporting requirements, international equity compensation and compliance, the devaluation of the US dollar and expansion into new territories with specific focus on navigating the uncharted waters of Africa.

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.

PwC health and wellness touchstone survey results
PricewaterhouseCoopers Human Resource Services provides the results of our first-ever Health and wellness touchstone survey. The survey — which explores corporate wellness strategy with specifics around overall wellness and disease management, addressing increased costs and medical/prescription plan design — was conducted throughout the month of April 2008 and received over 550 responses from US companies across a wide range of industries.

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.


IFRS

The uncertain future of LIFO
This article examines a potential exception to the LIFO conformity requirement that could allow the use of LIFO for qualifying companies even after their conversion to IFRS, and discusses planning opportunities that may be available to US taxpayers to help them alleviate the tax burden caused by a future LIFO termination.

Currency gains and losses and IFRS: Tax implications of IFRS on foreign currency gains and losses resulting from long-term intercompany loans
Intercompany loans may have the risk of fluctuating currency valuation. However, currency risk on debt not intended for repayment may receive what some perceive as "beneficial" treatment under some local GAAP financial accounting standards, where currency fluctuation is recorded directly in the balance sheet with no impact to profit.

IASB's proposed income tax standard: The responses are in...
In March 2009, the International Accounting Standards Board (IASB) issued an Exposure Draft proposing significant changes to the current international standard on accounting for income taxes, IAS 12, Income Taxes. The Exposure Draft was open for comment through July 31, 2009, and the IASB received more than 160 responses on the proposals. This article provides a summary of the overall response to the Exposure Draft, and further highlights some of the common themes from responses to the detailed questions posed by the IASB.

Transfer pricing and IFRS: Implications of IFRS on cost sharing arrangements
This article addresses the potential impacts that adopting IFRS accounting policies, particularly those related to revenue and expense recognition, may have on an organization's existing and future cost sharing arrangements.

A tax perspective on implementation, IFRS-Tax action plan (March 2009)
This IFRS publication provides an illustrative action plan that your company’s tax function can use to assess the actions necessary to implement IFRS within the company’s specific timeline.

Implications of an IFRS conversion on property, plant and equipment from a US tax perspective For capital-intensive businesses, including companies in the manufacturing and utility industries, PP&E may account for over 25% of their balance sheet's total assets. From componentization to measurement and asset impairment differences, the conversion from US GAAP to IFRS has the ability to impact the financial reporting of many organizations. In addition, these differences may also have implications on a company's tax accounting, compliance, planning, processes, and systems.

Implications of an IFRS conversion on the US research & development tax credit
Kendall Fox, a partner, John Scacco, a director, both with PricewaterhouseCoopers’ R&D tax credit practice and Luke Cherveny, a director, with PricewaterhouseCoopers’ IFRS national tax practice examine what, if any impact there is on the application of existing R&D tax laws.

Income tax accounting under IFRS: A look ahead
This publication is the first in a series of articles that explores how the proposed IASB changes might impact companies.

Converting to International Financial Reporting Standards: Planning considerations for US tax executives
This publication will help your company answer the following questions: 1) Why is it important to begin planning now for the conversion to IFRS? 2) What are the most significant planning considerations for the global tax function? and 3) How and when should an organization start planning for the IFRS conversion process?

Tax departments bracing for IFRS: Survey
This articles examines how the merging of US GAAP and IFRS while years away, is causing companies to examine the potential tax implications of the future convergence.

IFRS, US GAAP, and US tax accounting methods
This publication attempts to identify circumstances where tax accounting method changes may be required or desired and where Schedule M computations may change during an IFRS conversion.

Implications of IFRS Conversion on US tax accounting methods
This publication details key considerations, as well as potential opportunities and drawbacks, related to the accounting changes that will result from a conversion to IFRS.

Tax implications of an IFRS conversion on debt arrangements
This article provides a basic understanding of the potential impact a conversion to IFRS may have on a company's debt planning strategies.

< Accounting for employee benefits under IFRS
This whitepaper outlines how the conversion to IFRS affects employee benefit plans.

Stock option award under IFRS: An analysis of the potential impact
PwC has developed this publication to assist you in understanding the impact of IFRS on existing and new share-based payment plans. The consequences of a move to IFRS will be important as the move may affect cash taxes and will certainly significantly impact financial reporting, systems and processes.

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.


International tax

Headquarters cost studies: time to review processes and procedures
In today’s economic environment, companies are reviewing all business activities as they search for potential cost savings. For US-based multinational corporations with significant US headquarters activities, a study of the costs and expenses associated with those activities can help achieve that goal.

Aligning global business models and tax planning
This article addresses three fundamental areas that multinational companies must address to achieve an integrated global structure: profit alignment, attribute management, and treasury management.

Challenges of structuring business integrations in India
This PwC international tax services publication addresses the challenges of doing business in India.

To the point
This PwC publication series addresses contemporary issues and is meant to be impactful, insightful, and concise. Each quarter we plan to address select topics that are of immediate interest to directors.

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 Services

Controlling employment tax costs in a declining economy
This article addresses the issues and opportunities associated with controlling employment tax costs in a down economy.

State and local tax trends affecting businesses in 2009: Looking back, looking ahead
In 2008, the world began facing an economic crisis of confidence, to say the least. State and local governments, hardly immune from the difficulties of this past year, continue to change their laws in efforts to increase revenues. This year's journal is intended to help you work through the 2008 changes.

SALT update alerts
In 2008, PwC published an article titled Michigan’s next bold experiment: From the SBT to the MBT, in the State and Local Tax Services annual thought leadership journal State and local tax trends affecting businesses in 2008: Looking back, looking ahead. The article spells out the details of the 2007 transition from the Single Business Tax to the Michigan Business Tax, a two-pronged tax based on both gross receipts and business income.

Since the adoption of the MBT, the state legislature and the Department of Treasury have been amending and interpreting the new tax. Given the enormity of the change — the complete abandonment of one tax system for another — taxpayers and tax advisors have eagerly awaited these amendments and interpretations, which will have a significant impact for businesses as they gear up to file their initial MBT returns for 2008.


Tax accounting


Debt restructurings and bankruptcy: Accounting, tax and FAS 109 considerations
This paper provides an overview of bank restructuring transactions and events from both a financial reporting and income tax perspective.

Seven principles to consider when preparing a tax provision for subsidiary or carve-out financial statements
While not all-inclusive, this paper explains several key principles, which, if kept in mind, will enable preparers to manage a carve-out tax provision process more smoothly.

Fair value accounting: Tax considerations
This paper highlights the significance of the movement toward fair value accounting to those responsible for company tax matters. It addresses the trend from the perspective of each of several diverse areas in which tax matters intersect with fair value measurement.

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.

The quarter close
A PwC quarterly publication designed to keep you informed about the latest accounting and financial reporting issues.


Tax function effectiveness

Managing the tax function through a weak economy
PwC tax function effectiveness whitepaper outlining options to consider when evaluating the operational perspective of the tax function. This article first appeared on CFO.com.

Driving performance effectiveness in the finance and tax function
This paper identifies common impediments, processes, and synergies among the finance and tax functions. A focus on the critical interdependencies between key roles and processes, from a data, technology, people and workflow perspective, will allow for a more holistic view than has historically been taken. Because much of the same data is used by both functions, companies can create significant value by applying the same finance transformation approaches to challenges within the tax function.

Investing in tax operations: Making the case
To remediate or avoid these outcomes, many tax organizations are taking a fresh look at their operating strategies and seeking innovative solutions to transform their tax operations to meet or surpass the expectations of their stakeholders. This search for solutions has led many tax professionals to realize that technology can significantly aid in the effort to maintain or improve their effectiveness.


Transfer Pricing

International transfer pricing 2009
Now in its eleventh edition, PricewaterhouseCoopers' International transfer pricing 2009 is an annual review which provides general guidance on a range of transfer pricing issues in 65 countries. The publication explains why transfer pricing is of fundamental importance to multinational enterprises.

As its author, Nick Raby, demonstrates, it is vital for every company to have a coherent transfer pricing policy which is responsive to the rapidly changing markets in which they operate. The book not only shows why sound transfer pricing policies must be developed within reasonable timescales, but also why such policies need to be re-evaluated regularly to allow for changes in the business.
Transfer pricing in a recession
This publication addresses how companies can make the most of difficult economic conditions outlining how to use benchmarking data to document present and past transfer prices, and demonstrates how the judicious use of both existing and new advance pricing agreements can help them defend, document, and optimise their intercompany transactions.

Transfer pricing and the green agenda
The green agenda will unquestionably trigger many transfer pricing issues. To reap the benefits and achieve the best results, companies should start now to tackle the issues head-on as soon as they arise. By acting now, forward thinking companies will realise long-term benefits to having the best possible transfer pricing solution that provides robust compliance and creates conditions that result in significant tax savings.

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 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 perspectives: The emerging perfect storm of transfer pricing audits and disputes
This publication focuses on several important global dispute resolution topics, including: recent developments involving the taxation of PEs; recommended improvements to APAs and Mutual Agreement Procedures (MAPs) around the world; and best practices in the global dispute resolution arena.


Washington National Tax Services (WNTS)

10Minutes on tax reform
10Minutes on tax reform provides PwC's perspectives on the political and economic events shaping the tax reform debate, and provides steps companies should be taking now to anticipate both risks and opportunities from likely tax reform scenarios, and prepare for potential outcomes

Business tax outlook 2009 & beyond
Major challenges are facing the US income tax system, strengthening the impetus for tax reform, a prospect that congressional tax-writing committees and the presidential candidates have been heavily focused on. For corporations, it is more important than ever to understand how potential tax reform outcomes may impact their business.

Controversies overapplying Section 263A capitalization rules
IRS scrutiny of uniform capitalization issues increases the need for taxpayers to review their Section 263A computations, particularly with respect to such items as contingent royalties and negative costs.

The corporate tax conundrum
This background paper describes the taxation of corporate and non-corporate 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 Services 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.

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.

Reducing risk: What every multinational company should know about international tax information reporting and withholding
Washington National Tax Services article outlining what every multinational company needs to know about international tax information reporting and withholding to minimize corporate risk.

Tax policy in transition: 2009 tax legislative outlook
In this publication, PwC's Washington National Tax Services (WNTS) offers a preview of the tax landscape facing Congress, including economic recovery legislation, comprehensive tax reform proposals, tax-related priorities such as healthcare reform, climate change, and energy independence, and other tax policy matters of importance to today's business leaders.

Total tax contribution: How much do large US companies pay in taxes?
PwC survey of taxes paid by corporations, using the Total tax contribution framework commissioned by the Business Roundtable.

What you need to know about the coming debate on tax reform: Risks and opportunities for US business
PwC tax whitepaper that examines political and economic events that are establishing the environment for tax reform. The paper outlines how corporate tax reform presents both risks and opportunities for US business that companies should begin to evaluate.


Industry sector publications



Tax benchmarking



PwC's industrial products tax leadership team released the 2008 tax benchmarking survey for the chemical, industrial, metals, and transportation & logistics industries. In addition to providing insight regarding the regulatory and global tax environment, these studies allow companies to assess how the drivers of their effective tax rates and overall standing compare with those of their industry peers.

 


Automotive



Intellectual property in the automotive industry: Transfer pricing aspects
This paper addresses the transfer pricing principles in the context of an automotive group, as some characteristics of the auto industry can make the analysis different to other sectors and, consequently, may create more conflicts between taxpayers and their revenue authorities.

 


Insurance

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.

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.


Real estate

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.


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.