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Developments in multistate taxation.
August 1, 2007... Federal
On May 25, 2007, President Bush signed the Small Business and Work Opportunity Tax Act of 2007 (P.L. 110-28). The provisions of that bill extend the sunset date of the Work Opportunity Tax Credit (WOTC) from December 31, 2007 to...
IRS expands restrictions on "killer b" transactions.
August 1, 2007... Notice 2007-48, IRB 2007-25, 1.
Overview
Notice 2007-48, expanding on Notice 2006-85, shuts down the variation of the Killer B transaction in which a controlled foreign corporation (CFC) acquires stock in its parent from the parent's...
Analyzing deferred compensation arrangements under the Section 409a final regulations: a six-step analytic process.
August 1, 2007... This is the second installment of Stewart Reifler's Six-Step Analysis. This month, we present Steps III and IV. We presented Steps I and II in the July issue, and conclude with Steps V and VI is the September issue.
Six-Step Analysis...
Canadian taxation of outbound investment: an introduction.
August 1, 2007... This article is an overview outlining in summary form certain international considerations applicable under Canadian income tax law, and reviewing in very general terms the manner in which Canada taxes outbound investment. The overview also...
Royalties: challenging European customs' concept.
August 1, 2007... Introduction
The valuation of goods for customs purposes is a highly complex task, especially in cases where separate royalty payments are made. Lately, we've experienced that the European customs authorities take a particular interest in...