Corporate Business Taxation Monthly articles from April 2002

Corporate Business Taxation Monthly archives from April 2002

Notes from the editors.(Brief Article)
April 1, 2002... Corporate Business Taxation Monthly is the only monthly publication specifically committed to meeting the needs of corporate tax executives and their professional advisors. As such, Corporate Business Taxation Monthly continues to provide...

Litigating a tax controversy: forums and process.
April 1, 2002... A taxpayer's preference is always to resolve an IRS dispute without resorting to litigation, but the real possibility exists that there will be times when the IRS may be more willing to litigate than to concede or settle the dispute. If this...

Broadening the class of service providers: Suzy's Zoo and notice 2001-76.
April 1, 2002... A Tax Court opinion, recently affirmed by the Court of Appeals for the Ninth Circuit, provides interesting insights into when a taxpayer will be regarded as a producer, a reseller, or a service provider for inventory capitalization purposes....

Taxation of compensation and benefits. (Field Service Advice #FSA 200206003)
April 1, 2002... The IRS has recently issued a Field Service Advice (FSA) on the timing of a deduction for stock acquired as part of a company acquisition. This guidance may be helpful in planning transfers of shares in a merger or acquisition. FSA 200206003...

Tax accounting.
April 1, 2002... This month's column discusses Revenue Ruling 2002-9, which allows developers to depreciate "impact fees" paid to local governments to obtain permission to build. The ruling may pave the way for taxpayers to argue for similar treatment for other...

Corporate reorganizations: prearranged sale renders purported section 355 distribution taxable.
April 1, 2002... PREARRANGED SALE RENDERS PURPORTED SECTION 355 DISTRIBUTION TAXABLE The Tax Court recently held in South Tulsa Pathology Laboratory, Inc. v. Commissioner (1) that a distributing corporation's purported tax-free reorganization pursuant to...

WTO appellate body rules in favor of EU in EIE case. (World Trade Organization, extraterritorial income exclusion)
April 1, 2002... WTO APPELLATE BODY RULES IN FAVOR OF EU IN EIE CASE The Appellate Body (AB) of the World Trade Organization (WTO), in its report issued on January 14, 2002, ruled in favor of the European Union (EU) in its dispute with the United States...