By D. Clarke Norton and Paul B. Burns, FTI Consulting
Determining the locus of ownership of intangible property related to the development of new products and services is one of the principal challenges that tax managers in multinational enterprises (MNEs) face on an ongoing basis. Tax managers must balance non-tax corporate objectives, tax efficiency, tax risk management, and financial reporting considerations.
Since the mid-1990s, many MNEs have turned to cost-sharing (sometimes referred to as cost contribution) arrangements as a way to achieve these objectives. The cost-sharing rules (Treasury Regulations Section 1.482-7) adopted by the US Internal Revenue Service (IRS) in 1996, and the principles outlined in Chapter VIII of the 1995 OECD Guidelines, provide a flexible framework....
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The accounting rules in the United States for software‐as‐a‐service or "SaaS" companies are fundamentally different from the rules more traditional software licensing companies are required to follow.
The Ernst & Young Africa Business Center is our way to help companies navigate the challenges and opportunities of doing business across the African continent.
Proposed amendments to financial and disclosure requirements in the extractive industries sector will see a significant overhaul of existing standards and greater obligations on entities to declare information on a number of activities that currently may go unreported.
The new ‘fit and proper person’ test has introduced a raft of uncertainty into the taxation of charities and charitable giving. HMRC revised its guidance on Friday 9 July 2010 on the test but issues remain to be considered.
The Scottish Government today announced that a fourth round of funding for youth projects under the CashBack for Communities scheme is now open, with a funding pot of £2.5m, split across all local authority areas.
Since the Interim Management Statement was introduced in 2007, much of the debate and surrounding angst have focussed on the statement to be issued in the second half of the year.
IFRSs set down requirements for the measurement and recognition of profits, but if a UK company wishes to pay dividends out of those profits its directors must consider whether those profits are distributable.
Chancellor George Osborne delivered the Coalition government's Emergency Budget on Tuesday (22 June). The following summarises the points in the Budget likely to have a particular impact on charities and their donors.
The Pensions Regulator ("TPR") has for the first time issued a contribution notice of £5 million, ordering a Belgian company, Michel Van De Wiele, ("VDW") to make good a gap in the pension scheme of its UK subsidiary, Bonas UK Limited ("Bonas"), which it claimed had been placed into administration to avoid maintaining the fund. The contribution notice was issued on 29 June 2010.
