Compensation & Benefits |  FAS 109 |  Federal Tax |  International Tax |  Multistate Tax | Tax Operations | Transfer Pricing

• Plan amendments, processes, and procedures due on December 31 – bringing alignment between form and function.
• What to do if things go wrong – calculation corrections and possible remedial actions.
• Proposed regulations dealing with calculation of penalty taxes and determination of income inclusion as a result of violating the regulations.

• Section 409A issues, including severance pay and deadlines for nonqualified deferred compensation plan documents.
• Foreign pension plans – new treaty provisions, increased scrutiny of accruals, and claiming proper deductions for pension expenses.
• Sourcing of stock option income for mobile employees.
• Reporting for expatriate rule changes under the HEART Act.

• Legal entity structure issues, including allocation timing differences, tax-sharing agreements, and federal, state, and foreign tax filings.
• Scope issues affecting the financial statement audit, including the tax provision, inventory of deferred items, the potential need for a valuation allowance, and documentation.
• Other potential tax issues, including deferred taxes, taxes payable, tax rates, tax contingencies, and FIN 48 liabilities.

• Global tax planning that considers how each foreign jurisdiction has or will adopt IFRSs.
• U.S.-centric complexities of converting to IFRSs, including accounting methods, state tax issues, and potential challenges of reporting earnings and profits of foreign subsidiaries.
• Tax operational considerations, such as professional development, data collection, and software.

• Emerging issues that have arisen in the past year, such as FIN 48, valuation allowances, and LILO/SILO transactions.
• Standard-setting update on the income tax convergence project.
• Regulatory developments, including frequent SEC comments on filings.

• The final rules, highlighting key changes and concerns for buyers and sellers.
• Unlocking the mystery of the attribute reduction rule – the importance of understanding inside and outside basis and attributes by legal entity.
• Potential traps and planning issues, including new flexibility to preserve attributes of acquired corporations.

• The market for purchasing tax credits.
• Renewable and solar energy tax credits and the energy efficient commercial building deduction.
• New Markets Tax Credits.
• Additional synergies and pitfalls for overlapping applicable incentives.

• Sources and types of legal entity complexity.
• Tax and non-tax benefits of entity rationalization, including tax savings, back-office consolidation, and improved governance.
• Keys to effective rationalization, including comprehensive analysis, setting realistic targets, capturing the outcomes, and involving teams at all levels.
• Who should lead the effort and why.

• Luxembourg – recent tax planning ideas involving financing, intellectual property, holding, repatriation, trading, and private equity structures for multinational companies.
• Italy – tax basis step-up opportunities in extraordinary transactions and the new interest limitation deduction rules.
• Key developments in other foreign jurisdictions.

• Direct and indirect uses of built-in losses and earnings and profits deficits.
• Unexpected consequences of loss recognition.
• Maintaining flexibility when profits are unpredictable.

• Taxation by multiple states, including employer withholding requirements and allocation and credit rules.
• Federal limitations, including claw-back retirement income rules under Section 114 and proposed legislation on income tax thresholds for mobile executives.
• Stock option issues, including issues related to the state taxation of qualified and unqualified stock options.

• Opportunities – and potential pitfalls – of using technology to support the year-end accounting process.
• Approaches for global data collection and management, including software selection and implementation, data identification, configuration, and data interfaces.
• Fine-tuning the tax organization to be more scalable and agile.

• Innovative approaches for deploying tax personnel more efficiently.
• Establishing and fine-tuning project management, work plans, budgets, status reporting, and updates for key processes.
• Technology considerations, including methodologies for storing electronic work papers and tactics and tools for aligning tax technology with the provision process.
• Improving collaboration between tax and accounting personnel, systems, and processes.

• Common compliance challenges, including data input errors, miscoding of software, and uninformed decision making by accounts payable staff.
• How a self-audit can help identify sources of errors that lead to underpayment and overpayment of taxes.
• People, process, and technology to address problems.

• Hungary – advantages of and strategies for obtaining Advanced Pricing Agreements, the increasing focus on and sophistication of documentation reviews, especially benchmarking data, stronger penalties for documentation shortfalls, and tips for resolving audit issues through Competent Authority.
• Poland – pros and cons of applying for an APA, including certainty for strategic investments in a market with high penalty regime.

• JTPF achievements regarding a simplified pan-European transfer pricing approach.
• The EU Arbitration Convention's Code of Conduct – does it help taxpayers eliminate double taxation?
• The master file approach to EU transfer pricing documentation – is it improving compliance efficiency and is it a model for global documentation?
• Perspectives of individual governments and how the results of the EU Forum are implemented in practice.

Download our
program guide
(PDF)