Tax Quarry

Ashley Wicks, a true Southern Belle, is a fourth year associate in the Private Client Services and Business Advisory practice group at Watkins Ludlam Winter & Stennis P.A.  Ashley’s practice includes providing advice to clients on federal, state and local taxation issues, corporate finance deals and general business and corporate transactions.  Ashley has developed a niche practice advising clients about new markets tax credits used to provide capital to projects geared towards the low-income community.  In addition, her tax advisory practice also includes IRS collection matters, tax controversy work, overseeing state tax audits, as well as providing her research expertise to answer complex tax questions.    

What is the best part of your job?

I enjoy doing work that allows me to be creative and delve into the Tax Code in order to answer really complex tax questions.  For example, when I worked on a lien collection matter for a client and I was able to craft a resolution that the client was able to live with, it felt really rewarding.   When a client gets a notice from the IRS, it is really nice to be in a position where you can help them to satisfactorily resolve the issue and relieve their stress. 

What is the most challenging part of your job?

Balance.  In my area of practice you have to get used to the fact that everything that the client brings to you is an emergency.  When you have multiple clients with emergencies at the same time, you tend to drop everything so that you can assist them as quickly as possible.  I constantly have to remind myself to carve some personal time out so that I can respond to these emergencies with a clear and open mind. 

What do you do with the personal time that you are able to carve out?

I enjoy reading romance novels: Kimani Press Arabesque is one of my favourite series.  

I also must confess that I am a reality TV follower.  I like to watch Single Ladies and Real House Wives of Atlanta.  Outside of that, I always try to spend time with my parents, my sister and my friends.  I value my close personal relationships and try to invest as much time as I can to maintain them.   

Are you a member of any organizations?

I am active in a lot of organizations.  ABA and NBA are two organizations where I am really active.  My view is that it is important to be a part of something that is greater than myself.  Involvement in these organizations allow me to do that.

If you could have dinner with any person in history who would it be? Why?

I would have to say, Tupac Shakur.  I like reading his interviews because he always has something interesting to say.  He is very deep.  One of the quotes I find intriguing, he says:  “I am not saying that I am going to change the world, but I am saying that I am going to spark the mind that does change the world”.  It makes you think.  Tupac died before he had an opportunity to mature into his greatness.  He has or had a lot of power with his words, and I do not think that he truly had an opportunity to harness this power.

If you knew that you would be stranded on an island tomorrow morning, what one thing would you bring with you?

My iPhone.  Without my iPhone I couldn’t text my friends, search for directions or talk to my Mom – and I definitely can’t go a day without talking to my mom.

Describe yourself in three words or less.

Ambitious.  Charismatic. Creative.

To learn more about Ashley and her practice, feel free to contact her by email at [email protected] or by phone at (601) 949-4828.  Ashley will be happy to assist you with any business or tax related issue that you may have.

Written by Marsha Henry

August 26, 2011 OVDI Update:

Due to the potential impact of Hurricane Irene, the IRS has extended the due date for offshore voluntary disclosure initiative requests until Sept. 9, 2011.

In order to participate and be eligible for the 2011 OVDI, a taxpayer must submit their name, address, date of birth and Social Security number and should submit as much of the other information on the three-page Offshore Voluntary Disclosures Letter as possible on or before Sept. 9, 2011. An incomplete Offshore Voluntary Disclosures Letter must be amended (with the addition of any missing information) and submitted as quickly as possible.

A taxpayer may request an extension of the deadline to complete his or her submission. Taxpayers requesting extensions must submit their name, address, date of birth and Social Security number and should submit as much of the requisite information as possible with their written request for extension.

Requests for up to a 90-day extension must include a statement of those items that are missing, the reasons why they are not included, and the steps taken to secure them.  Requests for extensions must be made in writing and sent to the Austin Campus on or before Sept. 9, 2011 to:

Internal Revenue Service

3651 S. I H 35 Stop 4301 AUSC

Austin, TX 78741

ATTN: 2011 Offshore Voluntary Disclosure Initiative

Sandra Rosier is a Tax Director at the Canada Pension Plan Investment Board (CPPIB).  In her role as Tax Director she is responsible for supporting the CPP investment teams in various multijurisdictional investment transactions from a tax perspective.  Sandra’s practice focus includes, but is not limited to, providing advice for private debt, infrastructure investments, public market investing; and funds and secondaries transactions. 

Sandra began her tax career as a law clerk for the Supreme Court of Canada.  She then headed south to Boston to join Ropes & Gray.  It was not long before she realized that she was a true Canadian at heart.  Accepting a Tax Associate position at McCarthy Tetrault, she quickly settled back into the hustle and bustle of downtown Toronto life.  Sandra further fine-tuned her tax expertise, before making the leap to CPPIB, at Couzin Taylor as a Tax Associate and then at Ernst & Young as a Senior Manager in International Tax Services. 

What is the most interesting part of your job?

I really enjoy learning about the commercial and business dimensions of a transaction.  The Tax Director role allows me to be a bridge between CPPIB’s external advisors and the internal investment team.  To do this job well, you need to have enough knowledge to make you dangerous on a wide breadth of issues.  In my role as a Senior Manager at Ernst and Young I was able to work on a lot of big deals.  However, I was limited in how involved I could be in the entire deal.  At CPPIB, I have to see things from a business perspective so I am exposed to many issues beyond tax that might affect an investment transaction.  This, to me, is really exciting.  It keeps me on my toes.

What is your biggest challenge at work?

The learning curve.  I am fairly new in my role and coming from an accounting and law firm the nomenclature is very different than in a business environment like the CPPIB.  The CPPIB is a private equity investment environment.  Although I worked with clients as an external advisor, as an internal advisor the communication style and emphasis is different.  Legal jargon is not enough to excel.  You need to understand the business objectives and know how to articulate it using business language and terminology. 

Where do you see yourself professionally five years from now?

In the next five years I am committed to really learning the investment industry.  I hope to be an expert in this field so that I can provide seamless advice more intuitively and efficiently. 

What one thing would you bring with you if you knew that you would be stranded (indefinitely) on an island tomorrow morning on your way to work? 

It’s a toss-up between pictures of my kids and my IPod.  In all seriousness, the pictures of my kids would definitely win that toss.   My IPod is a strong second runner-up. 

If you could have dinner with one person in history, who would it be? 

It would have to be Billie Holiday.  She was gone too soon.  I would want to tell her how special and talented she was. 

Who is your role model?

My mother.  She is a poet, retired teacher and the most wonderful woman in the world.  She is a model of how to live a life of devotion to others. 

When you are not working, what do you do with your spare time?

I love to spend time with my kids.  I run recreationally and enjoy watching foreign films.

I also write fiction and publish an etiquette blog for lawyers.  You can find it at:  http://www.lawandstyle.ca . The name of the column is Bar Code.  Check it out when you have a chance.

Written by Marsha Henry

Department of Finance Canada Press Release dated August 19, 2011

The Honourable Jim Flaherty, Minister of Finance, today released for consultation a package of draft legislative proposals relating to the Income Tax Act and Income Tax Regulations concerning the taxation of Canadian multinational corporations with foreign affiliates.

The package includes revisions to the foreign affiliate reorganization and distribution rules originally proposed in a February 27, 2004 release. It also includes new proposals in place of the 2004 proposals which suspended certain gains from the sale of shares and other assets of foreign affiliates for the purposes of the surplus accounting rules.

Consistent with the approach adopted in a December 18, 2009 release in which other measures from the 2004 proposals were revised and simplified, the legislative proposals being released today are intended to be easier for taxpayers to comply with and for the Government to administer.

In its December 2008 report to the Minister of Finance, the Advisory Panel on Canada’s System of International Taxation recommended fundamental changes to Canada’s system of international taxation, particularly in respect of its exemption system for foreign source business income earned by foreign affiliates.

At this time, however, the priority of the Government is to encourage countries to enter into Tax Information Exchange Agreements with Canada and to provide exempt surplus treatment as an incentive to those which choose to do so. The measures released today are aimed at improving the current international tax system, which the Panel characterized as a “good one that has served Canada well.”

The Government remains committed to continuing its review and analysis of all of the Panel’s recommendations and consideration of further legislative amendments.

The attached Annex outlines the key measures proposed in today’s package, while explanatory notes provide further details.

References to “Announcement Date” in the draft legislation and explanatory notes should be read as referring to today’s date.

Interested parties may submit comments on the package until October 19, 2011. The Government will then proceed with legislation at an early opportunity to implement the amendments, taking into account comments received.

Comments can be sent to [email protected] or to:

Tax Policy Branch

Department of Finance

140 O’Connor Street

Ottawa, Ontario

K1A 0G5

Click here for a copy of the proposal or download the document: Download Foreign_Affiliates_Legislative_Proposal