10Minutes on bolstering corporate liquidity
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
Pharmacy benefit management savings in Medicare and the commercial marketplace and the cost of proposed PBM legislation, 2008-2017
Healthcare policy in an Obama administration: Delivering on the promise of universal coverage
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.
Round two of FATCA guidance: IRS Notice 2011-34 addresses priority concerns, revises earlier guidance, and introduces new concepts
IRS re-issues notice 2011-53: Addresses effective date of withholding tax under FATCA on payments to NFFEs
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.
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.
The Multistate Tax Compact: The Journey Continues
Losing Control: How varying real estate transfer tax treatment of entity interest transfers creates confusion for taxpayers
States will likely see a windfall from Camp's tax proposal
California real property taxation - Tips and traps of the state's property and transfer taxes
The Show-Me State Shows How It’s Done: Missouri Is a Model MTC State
The journey of the MTC's joint audit program
Multistate US tax issues for inbound companies
California Enterprise Zones replaced with temporary incentives
California regulations: Effective dates now on a delayed quarterly basis
Multistate tax compact, Gillette v. FTB
California Enterprise Zones: Short time to fully benefit from hiring credits
Tax Analysts exclusive: Conversation with Paul DeNard
Managing tax controversy challenges on the horizon
Tax transparency and country-by-country reporting
Tax policy and administration trends
Tax technology: Creating a strategic asset
Tax Notes International - Profit Splits Post-BEPS, Quantifying an MNE’s Intangibles
Integration, Fragmentation, and Global Value Chains - The Beginning of the End of the Arm’s-Length Principle?
Brave new world: The OECD’s Base Erosion Profit Shifting (BEPS) Action Plan poses immediate challenges for oil and gas companies
IRS's Information Document Request process: How to navigate the IDR process for US-based multinational enterprises
OECD Documentation, CBC Reporting Requirements Elevate Importance of Preparation in IT and Controllership Processes
The Long-Term Effects of Advertising Expenditures: Examining the Evidence
Avoiding double taxation in the oil and gas industry
Facilitating successful Advance Pricing Agreements for US-based multinational enterprises
Leading practices for managing the competent authority process for US-based multinational enterprises
PwC Partner Mike Danilack reflects on his time at the IRS LB&I
Michael Danilack, former Deputy Commissioner (international) in the IRS Large Business & International Division (LB&I), joined PwC's Washington National Tax Services. Michael shared his insights in an interview with Amy Elliott from Tax Analysts.
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.
Intellectual property in the automotive industry: Transfer pricing aspects
Understanding the preliminary guidance and request for comments regarding the implementation of FATCA (IRS Notice 2010-60)
Americas insurance digest
Continuing developments in the taxation of insurance companies
Ready, set, FATCA: How the new rules will affect insurers, and why early action is the best policy
Treatment of insurance companies under dual consolidated loss regulations