Corporate Business Taxation Monthly articles

Recent articles from Corporate Business Taxation Monthly

Developments in multistate taxation.
September 1, 2007... Federal Proposed bill (S. 1726) would establish physical presence as the nexus standard for all state business activity taxes. The bill would define "business activity taxes" as "any tax in the nature of a net income tax or tax measured by the amount of, or economic results of, business...

The IRS identifies another cross-border event as a "listed transaction".
September 1, 2007... IRS Notice 2007-57 adds a new category of listed transaction that involves loss importation. (1) The technique involves the most elementary of "planning" techniques: the domestic taxpayer arranges to reflect on its U.S. income tax return the loss leg of a hedge entered into by a foreign...

Victory for online seller in Louisiana: no affiliate nexus for BarnesandNoble.com.
September 1, 2007... Federal courts rarely get the opportunity to consider whether an out-of-state company has sufficient nexus to support the imposition of a state tax. Because the federal Tax Injunction Act (2) provides that a federal district court may not "enjoin, suspend or restrain the assessment, levy or...

Analyzing deferred compensation arrangements under the section 409A final regulations: a six-step analytic process.
September 1, 2007... This is the third installment of Stewart Reifler's Six-Step Analysis. This month, we present Steps V and VI. We presented Steps I and II in the July issue, and Steps III and IV in the August issue. Six-Step Analysis Continued V. Distribution/ Payment Provisions A. Permissible...

Vendor beware: drop shipments may result in unexpected sales tax collection obligations.
September 1, 2007... In today's business climate, lean inventories are essential to reduce business costs and remain competitive. Conversely, with the proliferation of the internet marketplace, customers expect immediate delivery. Drop shipments are an attractive way to satisfy these conflicting business demands....