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Multinational businesses headquartered overseas customarily conduct operations in the United States via local subsidiaries. These U.S. companies, often structured as domestic corporate taxpayers, support their global organizations' efforts in reaching [...]

The recently enacted U.S. anti-avoidance tax rules targeting hybrid mismatches undoubtedly cast a very wide net. The application of these rules poses substantial challenges for global businesses and international tax [...]

The use of U.S. limited liability companies (LLCs) as holding vehicles or operational business entities has become increasingly popular among U.S. taxpayers. Along with a remarkably flexible charter, U.S. LLCs [...]

In recent years, the proliferation of different methodologies in state apportionment has intensified the concerns over double taxation and the overall fairness of apportionment rules. Alternative apportionment provisions aim to [...]

The article highlights the need for effective planning and recordkeeping in revenue sourcing and apportionment of telecommunications companies operating in multiple jurisdictions in the U.S. in 2011. It discusses the Massachusetts Appellate Tax Board decision on communication firm AT&T, the Uniform Division of Income for Tax Purposes Act (UDITPA) and the application of the operational approach. It notes the relevance of the operational model to a range of information technology businesses.

The article discusses the need for collection agencies in the U.S. to implement local tax strategies to help minimize risks.It mentions about nexus, which is defined as a minimum level of contacts that a taxpayer must have with a state in order for that jurisdiction to impose a local tax. It asserts that when a firm has many activities within a state to be lawfully taxed by that state, the taxpayer have a nexus with the particular place.