Apple’s Double Irish With A Dutch Sandwich Goes Down Easy with SEC

By Phil Karter Senator Carl Levin (D-Mich.) may have tried to take a bite out of Apple (AAPL) in congressional hearings last May examining the company’s overseas tax structure, calling it “the holy grail of tax avoidance.” However, it appears that more than just Irish eyes are smiling on the company these days, for in … More Apple’s Double Irish With A Dutch Sandwich Goes Down Easy with SEC

Squib Note: Clarifying the 2013 Capital Gains Rates

It has been universally reported that under the newly passed American Taxpayer Relief Act of 2012, net capital gain tax rates have risen to 20% for taxpayers with taxable income greater than $400,000 for single filers and $450,000 for joint filers.  To clarify this broad statement, under section 102 of the new law, the higher … More Squib Note: Clarifying the 2013 Capital Gains Rates

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

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?

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