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Evolution of the Tax Home Concept as a Legal Term of Art (Penultimate Draft)

[Penultimate draft. Final version forthcoming in the Journal of Taxation.] Evolution of the Tax Home Concept as a Legal Term of Art (Penultimate Draft) Anthony Malik* INTRODUCTION Tax home is, particularly when considered in an international context, a curious legal term with a specific meaning that is at odds with what it superficially suggests. Counterintuitively […]

Cost Allocation Base Selection for Transfer Pricing Purposes

Published in the Journal of International Taxation, Thomson Reuters, Vol. 35, No. 4, April 2024. Cost Allocation Base Selection for Transfer Pricing Purposes By Anthony Malik INTRODUCTION The successful implementation of a cost-based transfer pricing policy necessitates the group of companies to devise robust internal cost allocation methodologies. The reasonability of the cost allocation method […]

Essential Tax Rules of Cross-Border Gifting

Published in the Journal of Financial Planning, Financial Planning Association, Vol. 35, No. 10, October 2022. Essential Tax Rules of Cross-Border Gifting By Anthony Malik Introduction Strategic gift planning, done usually to minimize or eliminate the estate and expatriation[1] taxes, is firmly within the purview of tax and financial advisors. The vast majority of gifting […]

Timing the Creditability of Accrued Foreign Taxes

Published in the Journal of International Taxation, Thomson Reuters, Vol. 33, No. 3, March 2022. Timing the Creditability of Accrued Foreign Taxes By Anthony Malik INTRODUCTION Compliance-oriented tax professionals are—in many cases, for very good reason—most likely to first turn toward material published by the Internal Revenue Service (“IRS”) via instructions to tax forms and […]

An Inquiry into the Factors Aiding Clemency for Foreign Corporations Requesting Protective Tax Return Filing Deadline Waivers

Reprinted with permission from the California Tax Lawyer, The State Bar of California—Taxation Section. An Inquiry into the Factors Aiding Clemency for Foreign Corporations Requesting Protective Tax Return Filing Deadline Waivers By Anthony Malik[1] INTRODUCTION Foreign corporations (“FCs”) often have varying degrees of U.S. business activities which in turn subject them to varying degrees of […]

Point Square Consulting Advises U.S. Senate on Reforming the IRS

Tony Malik of Point Square Consulting was busy meeting top government tax policy advisors and lawmakers in Washington, DC last week. Very simply, the major items Point Square Consulting advocated for during the deliberations included: Expanding the rights of taxpayers appointing legal representatives. Defining realistic goals for the IRS in light of recent tax reform and budget cuts. […]

Point Square Consulting Advises U.S. Legislature on Tax Reform

Tony Malik, our firm’s Principal Consultant, was busy meeting with eminent tax policy advisors and legislative directors on Capitol Hill in Washington, DC last week. Some of the critical items Point Square Consulting advocated for during the deliberations included: Elimination of severe international tax penalties imposed on taxpayers for minor instances of noncompliance with various tax laws. Electronic delivery of the […]

Tony Malik to Speak at the Atlanta World Trade Center’s International Business Exchange

Tony Malik of our firm has been invited by the Atlanta World Trade Center to present an overview of the U.S. international tax system. As guest speaker, Tony will focus on the tax rules and planning considerations for cross-border businesses. Scheduling details of the event are as follows: Date: Tuesday, March 14, 2017 Time: 8:00AM Location: City Club of Buckhead, 3343 Peachtree Road […]