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International assignment perspectives: Volume 5 International assignment perspectives: Volume 5
International assignment perspectives, prepared by PwC's global mobility consulting professionals, addresses some of the most urgent issues facing companies with globally mobile workforces.

 
Decision Points for Tax Policy: 2012 tax legislative outlook Decision Points for Tax Policy: 2012 tax legislative outlook
In this publication, PwC's Washington National Tax Services (WNTS) offers a preview of the key tax policy issues facing the Obama Administration and Congress in 2012, including the outlook for tax reform, deficit reduction measures, business tax provisions that expired at the end of 2011, individual tax provisions scheduled to expire at the end of 2012, and other tax policy matters of importance to today's business leaders.

 
IRS re-issues notice 2011-53: Addresses effective date of withholding tax under FATCA on payments to NFFEs IRS re-issues notice 2011-53: Addresses effective date of withholding tax under FATCA on payments to NFFEs
On July 25, 2011, the IRS re-issued Notice 2011-53 to clarify that the delayed effective date to withhold tax under FATCA applies to withholdable payments made to all non-financial foreign entities (NFFEs).

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.



Climate change

Energy tax incentives: Outlook in a lame-duck Congress
This article discusses the various energy tax legislative proposals that might be considered in a lameduck Congress or that could be part of new energy legislation that may be proposed in 2011. Among the proposals likely to be considered are the tax provisions included in business tax extenders, climate change, and national renewable energy standards legislation.

Appetite for change: Global business perspectives on tax and regulation for a low carbon economy
Climate change is testing the ability of the world's leaders to develop effective environment policies, and many — in and out of governments — are frustrated with the pace of negotiations. This survey examines attitudes in the international business community towards environmental regulation, legislation and taxes.



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 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.



Indirect Tax

Shifting the balance: From direct to indirect taxes
This publication from our global indirect taxes network, tracks the development of indirect tax regimes worldwide and looks at how some of the key aspects of these regimes compare across major territories and regions.


Global information reporting

Round two of FATCA guidance: IRS Notice 2011-34 addresses priority concerns, revises earlier guidance, and introduces new concepts
The second piece in our FATCA whitepaper series provides an executive summary of the key points contained in Notice 2011-34, as well as a more in-depth analysis of the seven sections outlined in the notice with a glossary of defined terms.


IFRS

Implications of IFRS on M&A activity from a US tax perspective
This PwC article addresses how the adoption of IFRS accounting policies will interact with the US tax laws associated with the life cycle of a corporation.

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.

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 PwC’s R&D tax credit practice and Luke Cherveny, a director, with PwC’s 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

Paying Taxes 2012
Paying Taxes, is an annual study from PwC, the World Bank and IFC, now in its sixth year. It measures the ease of paying taxes across 183 economies worldwide, covering both the cost of taxes and the administrative burden of tax compliance.

10 Minutes on Investing in Africa
As worldwide investors vie for a piece of the action, the expectations of African stakeholders have risen. To succeed, investors will have to look beyond dazzling returns and one-off projects, and sign on as participating partners in Africa’s long-term growth and development.

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 extensive guide provides an up-to-date overview of the corporate and individual tax rates and rules in operation in over 146 countries.


State and Local Tax Services

Salt trends, a PwC state and local tax publication
PwC's sixth annual SALT thought leadership journal. This year's journal addresses some of the key 2010 state and local tax issues and changes, and how they may affect your business operations in 2011 and beyond.

 


Tax accounting

Deferred taxes on foreign earnings: A road map
Whether for the purpose of disclosure or recording the liability, significant judgement must be applied in measuring the deferred taxes on foreign earnings. Management needs to make assumptions about the operations of its business and consider the impact of planning opportunities.

Tax indemnification arrangements: Navigating the financial reporting
Income tax indemnifications are established in a variety of transactions, including business acquisitions, corporate spin-offs and initial public offerings (IPOs). Accounting for an income tax indemnification arrangement depends upon whether the company is obligated to the taxing authority, the relationship between the parties and the type of transaction. This paper provides a framework to apply in determining the appropriate accounting.

Understanding financial reporting for green and stimulus incentives
This PwC paper outlines certain financial reporting implications that occur when taking advantage of green energy tax incentives.

Goodwill impairment testing: Tax considerations
Numerous tax law and tax accounting considerations can impact whether there is an impairment of goodwill as well as the amount of impairment. This paper discusses five primary tax focal points, beginning at the outset of step 1 with the determination of the fair value of the reporting unit.

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.

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

Transfer Pricing Perspectives - Sustainable transfer pricing in an era of growth and business transformation
Written for the PwC 2011 annual transfer pricing conference, Perspectives: Sustainable Transfer Pricing in an Era of Growth and Business Transformation, addresses some of the fundamental changes taking place in the tax landscape and provides additional content and depth to the conference sessions. Topics covered in this edition include Russia's new transfer pricing rules, the role of risk in transfer pricing, successful management of the transfer pricing audit process, APAs in Asia Pacific, and transfer pricing for financial transactions.

The IRS's renewed emphasis on transfer pricing
Taxpayers should review their transfer pricing policies and documentation to ensure that they will withstand expected increased scrutiny by the IRS.

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 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.



Washington National Tax Services (WNTS)

Tax policy in a deficit-driven world: 2011 legislative outlook
In this publication, PwC's Washington National Tax Services (WNTS) offers a preview of the challenges facing the new Congress in 2011, including the outlook for tax reform, deficit reduction measures, energy tax incentives, health care issues, and other tax policy matters of importance to today's business leaders.

Why US business needs a reliable research incentive
Uncertainty surrounding the research and development tax credit continues as Congress failed to weigh in on its continuation.

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

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.

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.


Industry sector publications


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.



Financial services

Understanding the preliminary guidance and request for comments regarding the implementation of FATCA (IRS Notice 2010-60)
This PwC whitepaper provides a summary of the key points contained in the IRS Notice 2010-60, as well as a more in-depth analysis on the five sections outlined in the Notice with a glossary of defined terms.



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.

Ready, set, FATCA: How the new rules will affect insurers, and why early action is the best policy
PwC has published a new paper for the Insurance industry on FATCA. Here is your first look. The paper discusses the technical details of how the FATCA regulations affect the insurance industry, and what insurers can do now to prepare.

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 PwC's analysis of the regulations.