Reflections on the Ninth Circuit’s Decision in Amazon.com, Inc. v. Commissioner What is included when valuing intangibles assets for transfer pricing purposes? This is an issue that was addressed once by the U.S. Tax Court and more recently, the Ninth Circuit Court of Appeals. In a unanimous decision by the U.S. Court of Appeals for the Ninth Circuit (issued on August 16, 2019) the court of appeals affirmed ...

Under a FINRA proposal, firms with histories of misconduct would be required to set aside funds for anticipated arbitration awards. To read the full article in Financial Planning, click: New Rules for Firms that Hire Problematic Brokers. ...

As the regulatory landscape has evolved, compliance departments and the chief compliance officer (CCO) have become increasingly important, helping organizations to adapt. Many CCOs sit on boards and report directly to the chief executive. They are no longer on the outside looking in on business development; instead, they are a key cog in the machinations of the C-suite. To read the full article in Financier ...

The proposed rules include a way that taxpayers can group or aggregate separate trades or businesses and an anti-abuse rule designed to prevent taxpayers from separating out parts of an otherwise disqualified business in an attempt to qualify those separated parts for the Sec. 199A deduction. To read the full article in the Journal of Accountancy, click: Qualified Business Income Deduction Regulations Propo ...

FINRA has launched a helpline to provide firms with direct assistance and answers to general and routine FINRA related questions, as well as direct callers to the proper regulatory staff and other departments. The effort is part of its FINRA360 organizational improvement program. To read the full article in FinancialPlanning, click: FINRA Helpline Aims to Aid Smaller Firms, but Concerns Arise. ...

Officials at the SEC and FINRA have been talking a lot lately about how they have been ramping up their use of sophisticated technologies to root out questionable conduct among the firms they regulate.  It turns out that they are expecting advisors and brokers to do the same. To read the full article in FinancialPlanning, click: Regulators Want Firms to Ramp Up Fintech Accountability. ...

Understanding the fractions rule can enable tax-exempt organizations to invest in partnerships that hold interests in debt-financed real property without being subject to the tax on unrelated business income under Section 512.  Michael Hoffman, CPA, Washington, explains. To read the full article in The Tax Advisor, click: What Proposed Regulations on the Fractions Rule Mean for Tax-Exempt Organizations. ...

The Tax Rules Were Never Friendlier, But Changes May be on the Way The biggest loophole in the tax code may soon be coming to an end—at least according to the messages sent by the Obama administration and its recent budget proposals. The American Taxpayer Relief Act of 2012 (ATRA) set a whole new tone for most estate plans when it took the dreaded estate tax off the table. However, it is no secret that the ...

FLPs Remain a Viable Intra-Family Transfer Option, But Act Now The Internal Revenue Service has floated the idea of making regulatory changes to the implementation of section 2704, in this article the author gives us an update on the subject and underscores the need to facilitate intra-family transfers of businesses. ...