Current Corporate Income Tax Developments (Part II) - 2008
Article:
This article covers some of the more important developments in apportionment formulas, unitary groups/filing methods, administration, flowthrough entities, and other significant corporate state tax issues.
Published on January 22, 2013
Tax Practice and the Federal Criminal Code
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Tax practitioners and taxpayers can be prosecuted for crimes under the criminal sections of the Internal Revenue Code and under the general criminal provisions in Title 18 of the U.S. Code.
Published on May 11, 2010
Tax Court HoldsRepeatedlyThat Antarctica Is Not a Foreign Country
Article:
In 2007, the Tax Court in case after case decided that taxpayers cannot exclude income earned while in Antarctica under the foreign earned income exclusion provisions of Sec. 911.
Published on May 11, 2010
Partnership Returns Late Filing Penalties Increase
Article:
Late 2007 legislation brought changes to Sec. 6698, which provides for penalties against a partnership for filing a late or incomplete return.
Published on May 11, 2010
What Is Long-Term Care and Who Is Responsible for Its Cost
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Long-term care is defined in the Code as “necessary diagnostic, preventive, therapeutic, curing, treating, mitigating, and rehabilitative services, and maintenance or personal care services” for a chronically ill individual.
Published on May 02, 2010
Website Reviews
Article:
Reviews of websites of interest to tax practitioners.
Published on May 02, 2010
Tax Treatment of Payments in Common Pharmaceutical Agreements
Article:
The Service outlined its position on the treatment of the various types of payments under pharmaceutical collaboration agreements in a coordinated issue paper.
Published on May 02, 2010
Sweet Rewards State and Local Incentives Arrangements
Article:
Many state governments and local communities help businesses grow and expand by offering various credits or incentives for routine investments, for workforce training, or for more targeted behaviors, such as locating in an enterprise zone.
Published on May 02, 2010
President Signs Stimulus Tax Legislation
Article:
On February 13, 2008, President Bush signed into law the Economic Stimulus Act of 2008, which included several tax items among its provisions.
Published on May 02, 2010
Sec. 382 Ownership and Fluctuation in Value
Article:
For a corporation with more than one class of stock, the effects stock price fluctuations can play a significant role in determining whether use of the NOLs could become limited as a result of trading and other equity shifts.
Published on May 02, 2010
Restricted Stock in Acquisitions IRS Provides Much-Needed Guidance
Article:
Rev. Rul. 2007-49 provides valuable guidance in determining whether Sec. 83 applies to the receipt of restricted stock in taxable and tax-free reorganizations. However, many questions remain unanswered.
Published on May 02, 2010
Preaching Tax Compliance
Article:
Sec. 501(c)(3) restricts charities from influencing legislation or intervening in any political campaign or from benefiting insiders through private inurement. Ministers must tread carefully to prevent their preaching from crossing into politics.
Published on May 02, 2010
New Rules for Disclosure and Use of Tax Return Information by Tax Return Preparers
Article:
Newly finalized regulations should prompt all return preparers to evaluate their processes to ensure that they conform to the disclosure requirements of Sec. 7216.
Published on May 02, 2010
IRS Provides Procedures to Request Revision to Year of Change for Form 3115
Article:
The IRS provided procedures for taxpayers, under certain conditions, to request to revise the year of change for a pending Form 3115, Application for Change in Accounting Method.
Published on May 02, 2010
IRS Changes Its Position on Performance-Based Compensation for $1 Million Compensation Limit
Article:
The IRS ruled that an incentive plan is not performance-based compensation because it allows payments upon involuntary termination without cause by the employer, voluntary termination by the employee with good reason, or voluntary retirement regardless of whether the performance goals are met.
Published on May 02, 2010