This article asks whether tax planning advice can ever be effectively regulated by the IRS. The article first explores whether tax advice differs in kind from other forms of legal advice. Secondly, it looks at the clear regulatory distinction between the treatment of return preparation advice...

This paper discusses the issue of profit shifting and "aggressive" tax planning by multinational firms. The paper makes two contributions. First, it provides some background information to the debate by giving a brief overview of existing empirical studies on profit shifting and by describing...

This paper discusses the issue of profit shifting and ‘aggressive' tax planning by multinational firms. The paper makes two contributions. Firstly, we provide some background information to the debate by giving a brief overview over existing empirical studies on profit shifting and by...

This Article analyzes the incorporation decisions of relatively new, U.S.-based private business enterprises with global ambitions. Such startup firms generally organize as U.S. corporations. This Article theorizes this dominant structure and its exceptions, drawing from prior literature and...

This paper summarizes the key features of tax risk management and sets out the typical steps that should be followed. It follows a typical Six Sigma process in going about tax risk management. This paper discusses tax risk management, in particular, in the context of Section 404 of the U.S....

This paper was presented as part of a workshop to supply chain managers in 2006, on tax planning as part of a tax risk management process. The paper contains useful tools to conduct the appropriate tax risk management strategy, with tax planning as the focal point. The paper also deals...

The add-backs, adjustments, and other computations involved for individuals who incur a NOL, as well as the factors to consider in deciding if the carryback should be waived, can appear daunting.NOLs relate only to business income and deduction items, so an individual taxpayer must separate out...

The effective tax rate may be used to measure the impact of changes in a country's tax policy on a company's tax burden. Our study examines if the ownership structure and firm's governance mechanisms affect the ETRs and tax planning in Malaysian listed companies. Using a sample of 345 companies,...

This paper provides a practical overview and normative analysis of international tax planning ideas for entities who are establishing or restructuring their business affairs. In particular, in an international financial hub, such as Hong Kong, taxation advisors and lawyers need to be...