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Tax Refunds Available for Cost Sharing Arrangements Containing Stock Base Compensation

Tom Phalen Corporate Tax, Tax Services, Tax Strategy, Taxing Times

U.S. taxpayers that reported Cost Sharing Arrangements (CSAs) on tax returns which contain stock based compensation under IRC Section 482 should consider filing amended tax returns for prior tax years. This recommendation is based upon a July 27, 2015 Tax Court case, Altera Corp. v. Commissioner, where the court held that the tax regulations requiring stock based compensation to be …

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Ounce of Prevention is Worth a Pound of Cure.

Tom Brehmer Tax Services, Tax Strategy

My Dad was an engineer. I’m an accountant. For years, Dad complained that bean counters were the bane of his existence. He felt strongly that the individuals responsible for developing a company’s engine of growth should not be accountable to accountants. As a young public accountant, he infuriated me. After all, I worked for a Big Eight accounting firm. I …

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Transfer Pricing isn’t Tax Hocus Pocus

Tom Brehmer International Tax, Tax Planning, Tax Services, Tax Strategy, Taxing Times

It’s complicated. Here’s why. It’s about measurement and movement of value from one legal jurisdiction to another. It’s about addressing the tax implications attached to the values by each jurisdiction. It’s about planning for where you need cash. Moreover, it’s about understanding why you’re doing it. If you’re already doing business in multiple countries and want to establish appropriate pricing, …

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What Your Doctor And Accountant Have In Common

Tom Brehmer Tax Planning, Tax Services, Tax Strategy

In 1789, Benjamin Franklin wrote “‘In this world nothing can be said to be certain, except death and taxes.” Seems just as true today as when Ben said it originally. Today, with the volume of available diagnostic information on the internet, many individuals self-diagnose. Someone starts feeling bad and they immediately go online to see what they are dying from. …

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Why You May Be Repeating Past Tax Mistakes

Tom Brehmer Corporate Tax, Tax Strategy, Taxing Times

What does an ounce of prevention is worth a pound of cure mean in the context of corporate tax? Pretty simple, it means planning. The shareholders expect management to have a tax strategy and to execute on it. The problem is there are as many tax strategies as there are businesses! Here’s an example… One company wants effective tax rate …