July 2013

 
 
 

In an Emergency…Fax Form 911

In our prior articles on the IRS, we covered standard notices, the audit process, and the various avenues to resolution including going to Appeals and Tax Court. ... read more

 
 

Investing in Floating Rate Loans

In today’s investment landscape, the mounting uncertainty about growth and income from traditional investment sources has created a conundrum for yield-seeking investors. ... read more

 
 

Common Gifts and Factors Influencing Their Value

The American Taxpayer Relief Tax Act of 2012 (the “Act”), enacted on January 2, 2013, ended an 11 year period of uncertainty relating to estate tax exemptions and rates by making the agreed upon exemptions and rates “permanent”. ... read more

 
 

Dealing with the Secondary U.S. Tax Consequences Of Transfer-Pricing Adjustments

Imagine this: the transfer pricing report that has been in process is received after year-end (but before the tax return is due) and the conclusion is that the price the U.S. parent has charged its foreign subsidiary for intercompany transactions throughout the year is too high and needs to be adjusted downward. ... read more

 
 

Reforming Beneficial Taxation in Switzerland

The contemplated Corporate Tax Reform III (CTR III) will be a key element for the attractiveness of Switzerland as a location for multinational enterprises. It will be influenced by the ongoing tax controversy with the EU and the growing concern of the OECD with regard to profit shifting and base erosion, presenting challenging and dynamic circumstances.... read more

 

CONTRIBUTORS

   
  • Trevor Hancock
  • Andrew Bernard
  • Kerstin Heidrich (PrimeTax)
  • Diederik Hauser (Taxperience)
  • Sean Beznicki
  • Lee Sussman
  • Stefan Widmer (PrimeTax)
  • Sam Abbing (Taxperience)
 
 

 

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