Cost sharing arrangements between American Multi National Corporations (MNCs) and their foreign affiliates and subsidiaries, have, for some time provoked the concern of the Internal Revenue Service and the Treasury Deporatment. Were MNCs engaging in complex cross-border transactions for the sole purpose of reducing their overall tax liability? A 2006 Treasury proposal which seeks to stem abuses, though well meaning, may ultimately undermine U.S. competitiveness because the application of the so-called Investor Model to arms-length transactions provides strong incentives for MNCs to conduct their research and development activities off shore.
A perfect storm has materialized for tax directors of Fortune 1000 companies. Greater disclosure of segment data as a result of the Sarbanes Oxley Act, increasingly prehensile foreign tax authorities, and growing use of a shared services concept for managing global expenses, has made the allocation of headquarters’ expenses fraught with risks, and if managed correctly, opportunities too. I helped author this monograph along with a PriceWaterhouseCoopers international tax partner to generate awareness on strategies and tactics which can be used to manage risks associated with allocation of headquarters’ expenses and minimize the corporation’s marginal tax rate.
As wealth management continues to evolve, greater emphasis is placed on a wider range of related disciplines. I was hired by SEI Investments to help craft a series of plain-spoken, short monographs on discreet topics in estate planning which ranged from medical directives to selecting a guardian for your children.
The valuation of portfolio securities is the cornerstone of the investment management industry. Securities valuations represent a significant day to day responsibility for fund management and directors. However, market timing scandals, increasingly interlinked capital markets and a broadening of securities held in mutual funds have brought to light new thinking and new rules about the fair valuing of portfolio securities. I worked closely with professionals in Deloitte’s financial services and investment management practice to help author this white paper which discusses why fund managers and trustees must now operate within a broader context and apply fair value procedures in a fund’s daily operations rather than as a contingency procedure applied when the fund’s board and or management believes pricing or other valuation irregularities might be present.
Reaction to the wave of late trading and market timing scandals came in the form of the SEC’s compliance program for investment managers and advisors. This white paper which I helped author for Deloitte was written for compliance officers, c-level executives and board members of fund companies and provided them with a broad overview of the issues and implications issuing from this new regulatory initiative.
This article I wrote for T. Rowe Price shows that investors need to look at today’s expenditures not just in absolute terms, but also in terms of their potential future value. A family car for $380,000 anyone?
Leverage, sheltering of income and tax avoidance make calculating the real return on real estate tricky. This article, written for and published by Interbay Funding, a mortgage lender, does a deep dive on the nuances of calculating the real return on real estate.
Remember, it’s your job to make the case for why your loan should get funded, not the loan officer’s. The first step is a loan proposal that gets your foot in the door.
Though the Sarbanes-Oxley Act was made law in 2002, years later directors, chief executives and chief financial officers debate its meaning and its impact on the relationship between boards of directors and the management teams they monitor. In this piece, I worked with PriceWaterhouseCoopers summarizing the views of these constituencies as expressed in a syposioum held in New York City during the spring of 2004.
This article explores some of the basic concepts concerning how to determine the basis of assets you inherit or receive as a gift. This is a companion to an earlier article which explored basic tenants of determining cost basis.