Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges with the mounting demand. Our International Tax Group breaks down the hurdles for APMA and identifies important trends companies negotiating APAs should keep in mind. APMA staff increased 21% last year, but median completion time for an APA increased to 35 months (up from 33 months in 2020) APMA would need more … [Continue reading] about Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?
Our Unclaimed Property Team reviews California AB 2280, which would allow the State Controller’s Office to establish a new California Voluntary Compliance Program. The proposed VCP would be available only to certain holders To qualify for the … [Continue reading] about California Dreaming of a Voluntary Compliance Program
Have questions about the new Frequently Asked Questions for group health plans’ coverage of over-the-counter COVID-19 test kits? Our Employee Benefits & Executive Compensation Group addresses key provisions of the extensive requirements for plans … [Continue reading] about Testing for COVID and Your Kits for Free: Expanded Coverage of OTC COVID-19 Test Kits and Developments in Preventive Care
Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will still face uncertainties in the application of the foreign tax … [Continue reading] about What’s in a Name? Final FTC Regulations Rebrand the Jurisdictional Nexus Requirement
Oral argument before the U.S. Supreme Court in Hughes v. Northwestern University will have broader implications for both 401(k) and 403(b) plans. It isn’t always easy to read the tea leaves, but our ERISA Litigation Group offers key takeaways from … [Continue reading] about Supreme Court Offers Mixed Guidance on Future of Lawsuits Challenging Investments and Fees in 401(k) and 403(b) Plans