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Academic Journals
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From:Journal of Accountancy (Vol. 215, Issue 3)The IRS issued final regulations under Sec. 7216 that govern the circumstances in which tax return preparers can disclose or use certain limited tax return information (T.D. 9608). The regulations finalize with minor...
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From:Journal of Accountancy (Vol. 211, Issue 5)The IRS on Feb. 8 opened a second reduced-penalty voluntary compliance initiative for taxpayers' undisclosed offshore assets. The program is designed to bring money held in foreign accounts back into the U.S. tax system...
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From:Tax Executive (Vol. 63, Issue 1-2)March 7, 2011 On March 7, 2011, TEI filed comments with the Canadian Department of Finance and Canada Revenue Agency recommending amendments to the Harmonized Value-added Tax System regulations to make the reporting...
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From:The CPA Journal (Vol. 82, Issue 12) Peer-ReviewedIn 2006, Congress revamped the IRS's program for rewarding informants who disclose tax violations. The first beneficiary of the new program was a CPA, who received a $4.5 million reward when he discovered and disclosed...
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From:National Tax Journal (Vol. 62, Issue 1) Peer-ReviewedThis paper examines the implications for multinational firms of recent proposals to conform tax and financial reporting (i.e., book-tax conformity). Proponents of book-tax conformity argue that the current dual system...
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From:Tax Executive (Vol. 61, Issue 5)For the last several years, Textron, Inc. has been seeking to keep its tax accrual workpapers away from the prying eyes of the IRS. That struggle took a turn for the worse on August 13, 2009, when a divided U.S. Court...
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From:Tax Executive (Vol. 68, Issue 5)Leading the preeminent association of in-house tax professionals represents the ultimate combination of service and duty to our peers and profession and, for me, is a capstone to my thirty-plus-year career as a tax...
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From:Tax Executive (Vol. 68, Issue 6)As the year comes to a close, we have a natural tendency to reflect on the past twelve months. This year has been exciting and challenging. Brexit. Summer Olympics. The U.S. presidential elections. This also has been an...
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From:Journal of Accountancy (Vol. 221, Issue 2)The IRS posted instructions on its website (available at tinyurl.com/ o25av2f) for taxpayers or their CPA or other authorized representative to obtain copies of returns filed by thieves using the taxpayers' stolen...
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From:Journal of Accountancy (Vol. 220, Issue 5)The IRS issued proposed regulations that would update and clarify the rules regarding the penalty for failure to disclose reportable transaction information. Sec. 6707A imposes a penalty for failing to include on any...
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From:Tax Executive (Vol. 71, Issue 6)On May 31, 2019, TEI submitted comments to the Financial Accounting Standards Board concerning proposed changes to the disclosure requirements for income taxes in ASC 740. TEI's comments highlighted proposed changes that...
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From:Journal of Accountancy (Vol. 204, Issue 4)EXECUTIVE SUMMARY * Intermediate sanctions impose a penalty tax on key employees of certain tax-exempt organizations who receive unreasonable compensation, and on managers who approve it knowingly. * Intermediate...
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From:Tax Executive (Vol. 60, Issue 5)Congress and the Internal Revenue Service continue to view tax shelters with a high level of scrutiny, with Congress enacting legislation and the IRS promulgating rules designed to limit the ability of taxpayers to take...
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From:Tax Executive (Vol. 57, Issue 6)On September 27, 2005, Tax Executives Institute submitted the following written comments and testified in respect of the Multistate Tax Commission Draft Model Statute on Reportable Transactions and Inconsistent Filing...
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From:Notre Dame Law Review (Vol. 87, Issue 4)INTRODUCTION In 2009, the United States Court of Appeals for the First Circuit, sitting en banc, found that tax accrual workpapers prepared by in-house tax attorneys did not constitute work product. (1) The decision...
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From:The CPA Journal (Vol. 60, Issue 12) Peer-ReviewedSection 6114 of the Technical and Miscellaneous Revenue Act of 1988 imposed disclosure requirements on treaty-based return positions. Taxpayers are required to make disclosures by attaching a statement to their tax...
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From:Georgetown Journal of International Law (Vol. 45, Issue 4) Peer-ReviewedThis Note examines proposed changes to the U.S. Tax Code that would institute a "mark-to-market" tax accounting system for derivatives. From the perspective of international financial regulation, this change could lead...
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From:Journal of Accountancy (Vol. 209, Issue 5)The IRS extended until June 1 the comment period for its proposal to require large businesses to disclose uncertain tax positions and announced that it intends to make the requirement effective for tax years beginning...
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From:National Tax Journal (Vol. 61, Issue 4) Peer-ReviewedWe investigate the value of permanently reinvested earnings (PRE) of foreign subsidiaries of U.S. multinationals. We focus particularly on how firm value is affected by reinvesting P RE in financial rather than...
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From:Tax Executive (Vol. 61, Issue 1)Times have changed for corporate tax and financial executives. Once considered more of a departmental reporting function, the tax effect of actual and forecasted financial results is now a key point of integration...