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The United States Needs to Pass Legislation to Keep Research & Development in this Country

Tom Phalen Tax Strategy, Taxing Times

U.S. Research and development is key to development of new and improved products from the Apple watch to the latest vacuum cleaner. The U.S. was one of the first countries to grant favorable tax treatment for research and development performed in the U.S. Since then most of our trading partners grant similar R&D incentives (tax credits and additional tax deductions) …

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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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Is This Really All There Is?

Tom Brehmer Careers, Taxing Times

Big Accounting hires the best and brightest from top schools. Not only do they require academic excellence, but they seek candidates who are well rounded with outside interests. Every accountant recognizes that the work is a grind but the experience is invaluable. But…when you hit the wall and the rest of your life starts looking more interesting than your cubicle, …

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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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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 …