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IRS's Information Document Request process: How to navigate the IDR process for US-based multinational IRS's Information Document Request process: How to navigate the IDR process for US-based multinational
The IRS is moving towards 'cooperative compliance' in interactions between the IRS and taxpayers, and have updated their process for Information Document Requests for multinational companies.

 

Alternative dispute resolution: IRS Large Business and International Alternative dispute resolution: IRS Large Business and International
How are budget constraints in the IRS affecting affecting enforcement strategies? What options are available for resolving tax controversies? Beth Tucker of PwC's Tax Controversies and Regulatory Services explores how these budget constraints are driving changes in enforcement strategies and discusses available options to resolve tax controversies.

 

Doing business in the United States Doing business in the United States
PwC's US Inbound Tax's Doing business in the United States, provides a broad understanding of the basic tax implications of business operations in the United States as well as helpful insights into the tax consequences for non-US companies.

 

First Sale’ Strategy May Reduce U.S. Customs Duties, Joel Walters and Maytee Pereira, Inbound tax First Sale’ Strategy May Reduce U.S. Customs Duties, Joel Walters and Maytee Pereira, Inbound tax
For foreign-based multinational corporations (MNCs) doing business in the United States, the amount of customs duties paid on goods entering the U.S. often is not a top-level consideration. However, many of those companies might be leaving money on the table by paying more in customs duties than is necessary.

 

A conversation on the current environment with Joel Walters A conversation on the current environment with Joel Walters
Joel Walters, leader of the U.S. inbound tax practice and the global communications tax practice at PwC shares insight on the overall tax environment, public perception of multinational companies and the OECD/G-20 BEPS project.

 

CFOs, Tax Departments Face New IRS Approach to Delinquent Information CFOs, Tax Departments Face New IRS Approach to Delinquent Information
Financial executives at major organizations are increasingly collaborating with their tax departments and monitoring the expanded use of enforcement actions by the Internal Revenue Service under stricter guidelines for complying with information document requests (IDRs).

 

The unique challenges facing US inbound companies The unique challenges facing US inbound companies
Joel Walters, inbound tax leader for PwC US, explores how in-house teams can successfully navigate the new corporate tax landscape in light of increased scrutiny on tax planning processes, reporting requirements, and compliance initiatives.

 

Navigating a path forward: 2014 Tax Legislative Outlook
PwC's Washington National Tax Services (WNTS) offers a preview of the key tax policy issues facing the Obama Administration and Congress

 

Accounting for Income Taxes: 2013 Year-end Hot Topics
Calendar year 2013 has seen considerable activity across the global legislative and regulatory landscapes. We have seen changes to tax laws in several key territories, and certain legislative trends having a significant impact on income tax accounting. These developments, combined with an environment of economic uncertainty, have added to the challenges in accounting for income taxes.

 

Income tax disclosure
Numerous income tax accounting matters require the use of estimates, judgments, and other subjective information that can obscure the presentation in the financial statement accounts. Clarifying disclosures can enable users to gain a better understanding of the reporting entity’s income tax environment.

 

Global Annual Review 2013
In the current economic environment, the priority for governments worldwide – and Western governments in particular – is for their tax systems to generate the level of revenues they expect. This focus is reflected in a strong public sentiment that everyone should ‘pay their fair share’. Inevitably, ‘everyone’ is often defined in popular parlance as large corporations. And asked whether corporations are paying their fair share of tax, growing numbers of people appear to believe – rightly or wrongly – that the answer is "no".

 
Tax Accounting Services, Patent box and technology incentives: Tax and financial reporting considerations
This publication discusses key tax and financial reporting considerations of patent box regimes and other technology incentives.

 
Conversations: Mark Mendola
PwC US Tax Leader, Mark Mendola recently spoke with Tax Analysts contributing editor Jeremiah Coder on tax uncertainty, accounting firm services, and future tax policy.

 
The widespread reach of FATCA: How will it affect your business?
FATCA, the Foreign Account Tax Compliance Act, was enacted in 2010 to prevent and detect offshore tax evasion. Based on the name and a quick reading of the rules, FATCA seems to be directed at financial institutions. So, many global companies outside the financial services industry mistakenly believe that they are not affected. However, upon closer review, many realize the surprising fact that they have entities in their worldwide network falling under the purview of FATCA, or have operational areas that make or receive payments subject to FATCA.

 
Transfer Pricing Perspectives - Old challenges, new approaches: Mastering the transfer pricing life cycle Transfer Pricing Perspectives - Old challenges, new approaches: Mastering the transfer pricing life cycle
Today's transfer pricing rules are extremely complex. Multinational organisations are navigating operations in an ever-expanding globalised world, and the stringent, diverse transfer pricing requirements they face are daunting. As companies align their business supply chains, tax, and legal operating models to deliver sustainable financial benefits, the pressure is on to achieve these goals within a strict and divergent transfer pricing environment. The articles in this issue of Perspectives take a broad look at the different transfer pricing requirements and unique challenges companies are facing all over the world.

 
Worldwide Tax Summaries 2013/14 Worldwide Tax Summaries 2014/15
Worldwide Tax Summaries is a key reference tool for all tax practitioners. It draws on the breadth and depth of expertise offered by PwC, and gives you quick access to information about the corporate and individual tax systems in over 150 countries worldwide. The guide is available free of charge online, or as an ebook.

 


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.

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).




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

PwC Houston 2012 Second Annual Global Structuring Tax Forum
On November 8, a group of PwC Global Structuring Partners facilitated an engaging discussion with a group of senior tax professionals on a range of issues impacting the way multinational corporations align global structures to manage their US tax burden.

Corporate income tax – A global analysis
Corporate income tax is an important element of the Total Tax Contribution made by companies. The results of our joint study with the World Bank and IFC, Paying Taxes 2012, showed that based on the fact pattern of a standard case study company it accounts on average for 36% of the Total Tax Rate for that company around the world. Understanding more fully the impact of corporate income taxes and comparing the systems implemented around the world on a like for like basis is therefore important for governments, business, and the public at large. This study allows a like for like comparison across 183 economies and is based on research using data collected from contributors around the world for the Paying Taxes 2012 project.
Click here to download the study

Worldwide Tax Summaries 2013/14
Worldwide Tax Summaries is a key reference tool for all tax practitioners. It draws on the breadth and depth of expertise offered by PwC, and gives you quick access to information about the corporate and individual tax systems in over 150 countries worldwide.

Paying Taxes 2014 - The global picture
Paying Taxes 2014 is a unique study from PwC, World Bank and IFC which investigates and compares tax regimes across 189 economies worldwide, ranking them according to the relative ease of paying taxes. Paying Taxes looks not only at corporate income tax, but at all of the taxes and mandatory contributions that a domestic medium-size case study company must pay and considers the full impact of all these taxes in terms of both their tax cost and their compliance burden on business. Do you know what it really means for companies to pay their taxes around the world?

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.



State and Local Tax Services

Losing Control: How varying real estate transfer tax treatment of entity interest transfers creates confusion for taxpayers
In this October 2014 Bloomberg BNA Multistate Tax Report article, Sean Kanousis, Sam Melehani, and Reed Schreiter explore how state and local jurisdictions impose a tax on the transfer of a ‘‘controlling interest’’ in an entity that directly or indirectly holds real property and discuss the unique controlling interest transfer tax rules for commercial real property in two states — New York and Pennsylvania — and in two cities — New York City and Philadelphia.

States will likely see a windfall from Camp's tax proposal
In this September 29, 2014, State Tax Notes article, Hardeo Bissoondial Benjamin Bacon, and Kosha Udani explore four areas of the comprehensive tax reform proposal released by House Ways and Means Committee Chair Dave Camp, R-Mich. They say corporate taxpayers should examine those areas when considering the state tax impact on their businesses.

California real property taxation - Tips and traps of the state's property and transfer taxes
In this January 31, 2014, BNA Weekly State Tax Report article,Sean Kanousis, Sam Melehani, Reed Schreiter, and Adam Robbins explore how the intersection of California's real property tax and transfer tax cause significant issues for businesses owning California real property.

The Show-Me State Shows How It’s Done: Missouri Is a Model MTC State
In this October 21, 2013, Tax Analysts article, David Kennedy, Michael Herbert, and Bryan Mayster examine how Missouri allows taxpayers to make the Multistate Tax Compact equally weighted three-factor apportionment election and how such treatment may serve as a model for other compact states to follow.

The journey of the MTC's joint audit program
In this September 2013 article, Michael Herbert and Bryan Mayster explore the journey of the Multistate Tax Commission's joint audit program in light of the Commission’s early purpose of fighting for uniformity, efficiency, and compatibility of tax laws governing multistate businesses.

Multistate US tax issues for inbound companies
In this August 2013 International Tax Review article, Joel Walters, Maureen Pechacek, and Todd Roberts examine state and local tax issues facing inbound companies.

California Enterprise Zones replaced with temporary incentives
In this Special Report published August 19, 2013, in State Tax Notes, Matt Mandel, Kathy Freeman, Erin Bradley, and Dorothy Lo examine California's new economic development program and provide taxpayers with a roadmap for navigating the new scheme.

California regulations: Effective dates now on a delayed quarterly basis
In this June 10, 2013, State Tax Notes article, Matt Mandel and Dorothy Lo examine California's significant new change requiring standard effective dates for regulations.

SALT Trends
An e-series publication of timely thought leadership articles written by PwC state and local tax professionals focused on key state and local tax issues, developments and trends across income and franchise tax, credits and incentives, abandoned and unclaimed property, indirect tax (including sales/use tax and VAT), and employment tax.

Multistate tax compact, Gillette v. FTB
In this Viewpoint article published April 15, 2013 in State Tax Notes, Michael Herbert and Bryan Mayster of PwC's State and Local Tax practice examine Gillette v FTB , a state tax case with great significance for how interstate agreements are interpreted.

California Enterprise Zones: Short time to fully benefit from hiring credits
In this March 4, 2013, State Tax Notes Special Report, Matt Mandel, Dorothy Lo, and Matthew Avellar examine the changes to California's Enterprise Zone program.


Tax policy and administration

Tax Analysts exclusive: Conversation with Paul DeNard
Paul DeNard recently spoke with Tax Analysts about his career, the interaction between the domestic and international sides of Large Business & International tax, and his thoughts on the audit selection and personnel challenges facing the Service.

Managing tax controversy challenges on the horizon
Multinational enterprises are experiencing rapid change with respect to tax audits and controversies worldwide. Fundamental aspects of audits and controversies are evolving such as how revenue authorities are obtaining information, how they choose who will be audited, their choice of audit techniques, and how controversies are being resolved. And historical frameworks are being modified by more modern approaches. This report provides a closer examination of the broader trends crossing boards.
Click here to download the report

Tax transparency and country-by-country reporting
New tax reporting rules were adopted by the SEC in the US on 22 August and are the latest move in the global debate on tax transparency and country-by-country reporting. Now, for the first time, US listed companies in the extractive sector will be legally required to file information on the tax they pay in each country where they operate and they will need to report this at the project level. Similar proposals will be considered by the European Parliament this autumn with respect to EU companies. These new mandatory requirements will add to the voluntary framework which already exists under the Extractive Industries Transparency Initiative while further proposals are still being pursued by a coalition of civil society organizations. Given the recent developments it is increasingly important for companies (and our clients) to consider how these reporting requirements and frameworks may affect them.
Click here to download the study

Tax policy and administration trends
In our inaugural edition of Global trends we start by looking at the current status of some longer term tax developments. Some of the topics covered in this edition include stimulating growth and cutting deficits, base broadening and rate reduction, the shift from direct tax to indirect tax, the increase in inter-state collaboration to counter tax avoidance, economic substance and GAARs, and risk-based approaches to compliance and tax audits, amongst others.



Tax Reporting and Performance Improvement

Tax technology: Creating a strategic asset
How do manufacturing companies use technology in their tax functions? PwC and the Manufacturers Alliance for Productivity and Innovation (MAPI) surveyed more than 100 companies to uncover leading practices and challenges in applying technology to the tax function.

Tax Accounting Insights
This publication provides up-to-date information on tax accounting related developments including significant federal, state/local and foreign legislative developments, other significant tax technical matters which may have tax accounting implications, and information concerning the implications of converting to IFRS.

Key tax accounting considerations relating to recent Latin American tax law reforms
In late 2012, Mexico, Colombia, Nicaragua, and the Dominican Republic enacted tax reform packages that included income tax rate changes among other tax reforms.

Tax accounting implications of new Mexican tax legislation
In December Mexico passed legislation that may require tax accounting changes for organizations reporting under either US GAAP or IFRS.

Around the world: When is a tax law enacted or substantively enacted?
Companies reporting under US GAAP or IFRS need to understand when a change in tax law impacts the measurement of current and deferred income taxes.

Accounting for Income Taxes: 2012 Year-end Hot Topics
This publication is focused on the topics we believe will be most relevant to the preparation of 2012 year-end financial statements.

July - September 2012
In this release, we discuss decisions of the International Financial Reporting Interpretations Committee along with other accounting and reporting developments.

Tax function effectiveness: The vision for tomorrow's tax function
PwC's publication, Tax function effectiveness, is the definitive guide to the "why," the "what" and the "how" of managing an effective tax function.

Investing in tax operations: Making the case
PwC overview of how technology can aid in the effort to maintain or improve a company's tax effectiveness that includes improved internal controls, reduction in financial restatements and increased confidence in the tax function.

Driving performance effectiveness in the finance and tax functions
PwC discusses how to successfully identify common impediments, processes, and synergies among the finance and tax functions.



Transfer pricing

IRS's Information Document Request process: How to navigate the IDR process for US-based multinational enterprises
The IRS is moving towards "cooperative compliance" in interactions between the IRS and taxpayers. The IRS aims improve efficiency, transparency and dealings with taxpayers with the new information document request process, among other initiatives.

OECD Documentation, CBC Reporting Requirements Elevate Importance of Preparation in IT and Controllership Processes
In this Bloomberg BNA article, PwC authors, David Nickson, David Ernick & Elizabeth Sweigart, discuss readiness for the Organisation for Economic Co-operation and Development's (OECD) proposal for country-by-country (CBC) reporting and how multinationals can prepare.

The Long-Term Effects of Advertising Expenditures: Examining the Evidence
In this Bloomberg BNA article, PwC authors, Nicola Lostumbo and Arpan Sengupta, review the relevant literature on the economic useful life of marketing intangibles, specifically advertising, and recommend a direction to pursue in future research.

Avoiding double taxation in the oil and gas industry
Given the significant expansion of oil and gas companies globally, the need for industry players to align and coordinate local operations with corporate strategy has never been greater.

Facilitating successful Advance Pricing Agreements for US-based multinational enterprises
Advance Pricing Agreement (APA). In the United States, recent administrative and organizational changes in the IRS have resulted in a more practical and efficient APA process. Corporate taxpayers should re-evaluate the benefits and opportunities afforded by an APA given this new environment.

Leading practices for managing the competent authority process for US-based multinational enterprises
The term "Competent Authority" is used in income tax treaties to identify the designee or representative in each of the jurisdictions who will be responsible for implementing the treaty and its provisions.

Transfer pricing: Leading documentation practices for multinationals
Nearly 100 countries around the world have rules governing transfer pricing and nearly all require documentation either to be submitted or in place at the time the tax return is filed or when requested by the tax authority.

Former Treasury Official Expects OECD’s BEPS Project Will Improve, Not Jettison, Existing International Tax Rules
In this article published by Bloomberg BNA, former Treasury Associate International Tax Counsel David Ernick, who joined PricewaterhouseCoopers in February after eight years with the government, spoke with Kevin Bell about the direction of the Organization for Economic Cooperation and Development’s project on base erosion and profit shifting.

Substance 2.0: Aligning international tax planning with today's business realities
Since the first edition of Substance appeared in 2009, its subject —economic substance within the context of international tax planning— has only grown in importance. Indeed, across countries and within multinational bodies such as the EU and the OECD, authorities have launched numerous new initiatives focused on so-called “aggressive tax planning”, and tax challenges are on the rise. This book focuses on substance in corporate structures (tax residence, permanent establishments and beneficial ownership) and operating models (profit allocation), but the permanent establishment dimension has been developed more prominently. Domestic tax rules are now discussed for a total of 48 countries around the globe and we review how they interact with the OECD rules and EU law.
Click here to find out more and order the book

Transfer pricing - A critical success factor for offshore oil and gas companies
Almost 100 countries worldwide have established rules related to transfer pricing with most requiring some form of documentation for intercompany charges. As offshore oil and gas companies tend to have a significant number of related party transactions, industry participants are on the radar in many countries.

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)

A Principal Purpose: There Can Be Only One
Benjamin Willis explains why the IRS should adhere to the Supreme Court’s conclusion that the term ‘‘principal’’ is synonymous with ‘‘of first importance.’’

The phantom business purpose requirement for section 351
In this article, Willis explains why the section 351 business purpose requirement is a phantom.

Managing tax controversy challenges on the horizon
Multinational enterprises are experiencing rapid change with respect to tax audits and controversies worldwide. Fundamental aspects of audits and controversies are evolving such as how revenue authorities are obtaining information, how they choose who will be audited, their choice of audit techniques, and how controversies are being resolved. In our new publication, Managing tax controversy challenges on the horizon, we examine the latest cross-border trends in tax audits and controversies around the world.

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.