Tax Dispute Resolution Quarterly

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Applying sec.1032 to share-based awards for international employees By Andrew Gewirtz, Global Mobility Services, and John Crucs, International Tax Multinational employers often grant employees of foreign subsidiaries sharebased awards—stock options, restricted stock, and other equity-type awards— that are satisfied with stock of the U.S. parent corporation. This article in the May/June 2016 issue of Corporate Taxation explores some tax complications associated with the granting of share-based awards to international employees. Pre-filing agreement fee doubles in June and quadruples in 2017 On May 4, the IRS released a revenue procedure updating the rules and procedures for taxpayers seeking an IRS examination and resolution of specific issues relating to tax returns before filing the returns. Available only to taxpayers under the jurisdiction of the IRS Large Business and International division, pre-filing agreements or PFAs have been a popular and successful tool for the IRS and taxpayers alike. The program improves the quality of tax compliance and provides the taxpayer early certainty while reducing costs and other burdens related to tax administration. Rev. Proc. 2016-30 increases the user fee from $50,000 to: –– $134,300 for requests submitted after June 2, 2016 –– $218,600 for requests submitted after December 31, 2016 The new procedure also expands the scope of a PFA to include issues related to changes in methods of accounting requested under the automatic change procedures. Tax and accounting issues in debt restructurings and reorganization Changes in market conditions and economic uncertainty can cause any business to face financial challenges. These challenges may require an organization to reform its capital structure and even seek bankruptcy protection. Understanding the potential tax and accounting consequences of these decisions is critical to the organization’s future success and long-term stability. Senior professionals from the Tax Restructuring, Washington National Tax, and Accounting Advisory practices of KPMG LLP focused on significant tax and accounting issues in debt restructurings during an April 27 webcast. Among issues addressed are planning for cancellation of indebtedness income and net operating loss preservation, unique issues for partnership debt restructuring, worthless stock deductions, and accounting for troubled debt and debt extinguished in bankruptcy. © 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 568452
Tax enforcement trends Envisioning LB&I’s ‘Future State’ In this March 16, 2016, Tax Notes article, Mike Dolan argues that even though the new design for the IRS Large Business and International (LB&I) Division may give the agency more control over its resources, it may leave taxpayers with fewer options for remediating errors, securing certainty, and obtaining penalty relief (Read more...) Foreign currency options—Section 1256 contracts or not? A federal appellate court treated certain over-the-counter foreign currency options as section 1256 contracts (Read more...) New law creates new risks for partnership investments Legislation in November 2015 fundamentally changed the landscape of resolving tax disputes involving partnerships. (Read more...) © 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 568452
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Page 3 and 4: Contents Spotlight on compensation
Page 5 and 6: Spotlight on compensation and benef
Page 7 and 8: Golden parachutes By Compensation a
Page 9: FBAR reporting: Changes are in the
Page 13 and 14: New law creates new risks for partn
Page 15 and 16: A conversation with Greg Matson—E
Page 17 and 18: 2016 webcast series Around the worl
Page 19 and 20: Country by country, step by step: I
Page 21 and 22: © 2016 KPMG LLP, a Delaware limite

Tax Dispute Resolution Quarterly

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