The Benefits Of Seeking Competent Authority Relief For Proposed Transfer Pricing Adjustments

By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the former Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. My last blog post suggested that the best defense against transfer pricing assessments is the adoption of a globally consistent transfer … More The Benefits Of Seeking Competent Authority Relief For Proposed Transfer Pricing Adjustments

Transfer Pricing and How to Handle the “Double-Edged Sword”

By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the former Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. Transfer pricing among affiliated companies is the classic “double-edged sword”. When carefully designed, transfer pricing practices can cut a company’s effective … More Transfer Pricing and How to Handle the “Double-Edged Sword”

The Repatriation Dilemma Revisited

By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the recently retired Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. My recent post titled The Repatriation Dilemma: Cash may be King, but is Earnings Per Share the Ace of Trump? … More The Repatriation Dilemma Revisited

The Repatriation Dilemma: Cash May Be King, But Is Earnings Per Share Trump?

By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the recently retired Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. The financial press can’t stop talking about the amount of cash on corporate balance sheets. Journalists and arm-chair analysts alike … More The Repatriation Dilemma: Cash May Be King, But Is Earnings Per Share Trump?

LMSB’s Quality Examination Process – Ensuring its Application is “Fair and Balanced”

By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the recently retired Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. In case you missed it, the IRS recently introduced a new approach to its audit management process, called the Quality … More LMSB’s Quality Examination Process – Ensuring its Application is “Fair and Balanced”

All Hands on Deck: The Case for Broadening the In-House Discussion of Tax Issues

By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the recently retired Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. As the IRS sifts through dozens of comment letters on the proposed disclosure of uncertain tax positions, in-house tax officers … More All Hands on Deck: The Case for Broadening the In-House Discussion of Tax Issues

Tax Accounting Practices in a UTP Disclosure Environment

By David L. Bernard Tax Blawg’s Guest Commentator, David L. Bernard, is the recently retired Vice President of Taxes for Kimberly-Clark Corporation and a past president of the Tax Executives Institute. It is not too soon for in-house tax professionals to be thinking about how the disclosure of uncertain tax positions (required beginning with 2010 … More Tax Accounting Practices in a UTP Disclosure Environment