Corporate Business Taxation Monthly articles from August 2006

Corporate Business Taxation Monthly archives from August 2006

Multistate tax developments.
August 1, 2006... Colorado Effective May 30, 2006, a new computer software regulation replaces a previously withdrawb regulation (SR 7). Pursuant to SR 7, computer software is subject to sales or use tax if the transaction meets all of the following...

United States and Germany to amend income treaty.
August 1, 2006... The United States and Germany have agreed to amend their income tax treaty. A protocol ("the Protocol") that amends the United States--Germany income tax treaty was established on June nation of withholding tax on dividends paid by an...

New proposed estimated tax regs address timing of deductions.
August 1, 2006... The IRS and the Treasury withdrew previously proposed regulations and proposed new regulations concerning corporate estimated tax payments late in 2005. Those proposed corporate estimated tax regulations entail changes to the timing of...

Conflicts of interest under Sarbanes-Oxley: am I representing the rock or the hard place?
August 1, 2006... Introduction Congress enacted the Sarbanes-Oxley Act of 2002 (1) in response to certain perceived excesses caused by corporate officers and advisors that purportedly fueled a speculative stock market bubble. This bubble burst when these...

The application of Code Sec. 367 to Code Sec. 304(a)(1) transactions.
August 1, 2006... Federal income tax outcomes sometimes can be dependent on fictions, not on facts. Code Sec. 304(a)(1) measures federal income tax liability by analyzing a transaction that, as a matter of law or reality, does not occur. (1) Until very recently,...

Introducing DISC grouping and transaction-by-transaction methodology.
August 1, 2006... The DISC grouping process and the transaction-by-transaction method frequently impact the allocation of profits between a DISC and its related supplier: * A DISC and its related supplier can increase their Code Sec. 994 pricing benefits to...