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Accounting Firms

Accountants, journalist face tax leaks trial in Luxembourg

Accountants, journalist face tax leaks trial in Luxembourg

LUXEMBOURG (Reuters) – Two former employees of accountancy giant PwC go on trial in Luxembourg on Tuesday along with a French journalist, accused of leaking details of corporate tax deals that have fuelled global demands for reform. The case, coming 18 months after revelations dubbed LuxLeaks sparked accusations the Grand Duchy conspired with multinational companies to deprive […]

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IRS disagrees with decision that compensation for preparer malpractice wasn’t taxable

IRS disagrees with decision that compensation for preparer malpractice wasn’t taxable

AOD 2016-001,04/18/2016 In an Action on Decision (AOD), IRS has announced its nonacquiesence with a Tax Court decision that held that a portion of the amount a taxpayer received from an accounting firm that advised it to enter into an abusive tax shelter — as settlement in the taxpayer’s suit for the firm’s fees, losses […]

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Washington Alert – GAO on latest filing season at IRS; Sprint files suit against US Government over Ernst & Young misdeeds; Tax Policy Center revisits state and local tax deduction

Washington Alert – GAO on latest filing season at IRS; Sprint files suit against US Government over Ernst & Young misdeeds; Tax Policy Center revisits state and local tax deduction

The sheer scale of IRS’s operations during the filing season makes customer service one of the key challenges the agency faces on an annual basis, Jessica Lucas-Judy, acting director of strategic services at the Government Accountability Office (GAO), told the House Ways and Means Oversight Subcommittee on April 19. (GAO-16-578T) As described by Lucas-Judy, customer […]

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Delphi wins IRS inversion challenge & so is not treated as U.S. corporation

Delphi wins IRS inversion challenge & so is not treated as U.S. corporation

In a filing with the U.S. Securities and Exchange Commission (SEC), Delphi Automotive PLC (Delphi) announced that it is has won an appeal with IRS allowing the company to be treated as a U.K. tax resident for U.S. federal tax purposes. IRS had asserted that Delphi should be treated as a U.S. company under Code […]

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IMF, World Bank, UN, OECD form new group to stop tax erosion

IMF, World Bank, UN, OECD form new group to stop tax erosion

WASHINGTON (Reuters) – The International Monetary Fund and the World Bank said on Tuesday they are joining forces with other international organizations to cooperate on tax issues and develop new tools and standards to halt tax base erosion and evasion. The new grouping, which will also include the United Nations and the Organization for Economic […]

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Europe’s biggest nations join forces to end tax evasion

Europe’s biggest nations join forces to end tax evasion

WASHINGTON (Reuters) – Europe’s biggest nations launched a joint effort on Thursday to clamp down on tax evasion, responding to damaging revelations of financial wrongdoing by the rich and powerful in the so-called Panama Papers. The finance ministers of Britain, Germany, France, Italy and Spain agreed to share detailed data on the ownership of companies, […]

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Inversion rules will hit boutique M&A advisors hardest

Inversion rules will hit boutique M&A advisors hardest

NEW YORK (IFR) – Boutique advisory firms will lose out on millions of dollars in fees if the US Treasury Department’s latest proposed rules on tax-avoiding corporate mergers causes more M&A deals to fall apart. The clamp down – aimed at curbing deals in which companies move overseas to cut taxes – threw a number […]

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IRS provides new accounting method change form and transition period from old form

IRS provides new accounting method change form and transition period from old form

Ann. 2016-14 Form 3115, Application for Change in Accounting Method (Rev. December 2015) Instructions for Form 3115, Application for Change in Accounting Method (Rev. December 2015)) IRS has issued a revised Form 3115, Application for Change in Accounting Method, instructions to that form, and an announcement about the form that provides for a transition from […]

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Tax Experts Weigh in on Difficulties of Challenging Anti-Inversion & Earnings Stripping Regs

Tax Experts Weigh in on Difficulties of Challenging Anti-Inversion & Earnings Stripping Regs

Corporate inversions are back in the news this week following the Treasury Department’s release of temporary regs aimed at curbing the practice. Treasury also issued proposed regs aimed at the practice of “earnings stripping.” The regs received a mixed reaction, as expected, with some questioning whether the rules exceed Treasury’s authority. U.S. tax rules are […]

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EU’s Vestager says not penalizing U.S. firms or U.S tax system

EU’s Vestager says not penalizing U.S. firms or U.S tax system

BRUSSELS – Europe’s antitrust chief on Monday rebuffed U.S. criticism of her pursuit of Apple, Amazon and other U.S. companies over their tax deals, saying she was just doing her job to ensure a level playing field in the 28-country bloc. Competition Commissioner Margrethe Vestager’s comments came after U.S. Treasury Secretary Jack Lew earlier this […]

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Bad finance: Mind the non-GAAP @Twitter and beyond

Bad finance: Mind the non-GAAP @Twitter and beyond

NEW YORK (Reuters Breakingviews) – Twitter lost $521 million in 2015. No, wait – it earned $277 million of profit. The first figure is according to U.S. generally accepted accounting principles, or GAAP. The second is the alternative version created by the company led by Jack Dorsey, ostensibly to make the business easier to understand. […]

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Proposal calls for eight narrow clarifications for reporting cash flows

Proposal calls for eight narrow clarifications for reporting cash flows

The FASB released a proposal to clarify eight parts of its guidance on company cash flow statements. The proposal aims to clear up some of the most frequently asked questions about a complex area of accounting. The FASB on January 29, 2016, released for public comment a proposal to clarify eight narrow pieces of guidance […]

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In Comment Letters, Auditors Seek More Details on Fund Liquidity Proposal

In Comment Letters, Auditors Seek More Details on Fund Liquidity Proposal

The SEC proposed rules to strengthen the way mutual funds and exchange-traded funds manage their cash holdings so that shareholders can redeem their shares without causing a loss in value for other investors. The proposal includes a swing option that lets funds adjust their share prices to pass on trading costs to shareholders buying or […]

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Top U.S. official to meet EU antitrust team on tax

Top U.S. official to meet EU antitrust team on tax

BRUSSELS – A senior U.S. Treasury official will meet European Union antitrust officials investigating tax deals involving Apple and Amazon on Friday, the latest lobbying effort against a crackdown on U.S. firms. The meeting comes a week after Apple Chief Executive Tim Cook met European Competition Commissioner Margrethe Vestager, who is expected to rule on […]

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Phase two of effort to define a business in U.S. GAAP focuses on real estate deals

Phase two of effort to define a business in U.S. GAAP focuses on real estate deals

The FASB made several key decisions in its effort to clarify accounting for partial sales of nonfinancial assets, an important topic in the real estate industry. The effort is considered part two of the board’s wider project to improve the definition of a business. The FASB on January 6, 2016, worked on a series of […]

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EU mulls changes to national corporate tax laws to tackle abuses

EU mulls changes to national corporate tax laws to tackle abuses

BRUSSELS (Reuters) – The European Commission will propose next week that EU countries’ corporate tax legislation be amended to tackle multinationals’ tax avoidance schemes, EU officials said on Thursday. Multinational corporations have long been in the sights of European Union authorities due to the steps they take to reduce their tax bills. In a new […]

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Going concern staff paper scheduled for publication in first half of 2016

Going concern staff paper scheduled for publication in first half of 2016

The PCAOB is planning to issue a consultation paper on the audit standard on going concern warnings in the first half of 2016. Investors believe the current guidance is flawed and want earlier warnings when companies are in such deep financial trouble that their survival is in doubt. The PCAOB is planning to issue a […]

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Dutch say will lead EU fight against multinationals’ tax avoidance

Dutch say will lead EU fight against multinationals’ tax avoidance

BRUSSELS (Reuters) – The Netherlands will be at the forefront of efforts to combat multinationals’ tax avoidance, its finance minister said on Friday, amid a dispute with the European Commission over his country’s tax treatment of Starbucks. The Commission, the EU’s executive arm, will propose a new set of binding rules by the end of […]

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Regs set distribution amount for non-functionally integrated Type III supporting organizations

Regs set distribution amount for non-functionally integrated Type III supporting organizations

T.D. 9746, 12/21/2015, Reg. § 1.509(a)-4 IRS has issued final regs that set out the amount that a non-functionally integrated (NFI) Type III supporting organization must annually distribute to its supported organizations. The regs reflect changes to the law made by the Pension Protection Act of 2006 (PPA). Background. Tax-exempt charitable organizations that are private foundations […]

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Shareholder-employee’s payment in merger included both ordinary income and capital gains

Shareholder-employee’s payment in merger included both ordinary income and capital gains

Brinkley v. Comm., (CA 5 12/16/2015) 116 AFTR 2d ¶ 2015-5520 The Court of Appeals for the Fifth Circuit, affirming the Tax Court, has concluded that payments received by a shareholder-employee and founder of the company in a merger with Google, although nominally for the exchange of his stock, was partly compensation for services rendered. […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney