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International taxation.
December 1, 2006... Part I. Foreign Tax Credit Technical Taxpayer Rule
The Treasury and IRS issued proposed regulations in the foreign tax credit area, Proposed Reg. [section] 1.901-2(f) and (h), on August 3, 2006, that would revise the "technical taxpayer...
State and local tax aspects of corporate acquisitions.
December 1, 2006... Background
Historically, the state and local tax aspects of corporate acquisitions received little or no attention from tax lawyers or other professional advisors, at least prior to the closing of the acquisition. This is much less true...
The confusing world of DISC accounts receivables.
December 1, 2006... The DISC accounts receivable provisions are befuddling to both exporters and tax practitioners alike. (1) These DISC accounts receivable provisions cross-cut three sections of the Internal Revenue Code and rely on regulations nestled within...
The transfer of professional goodwill.
December 1, 2006... A Professional practice is identified with the professional who cleans your teeth, prepares your tax return, sues your tenant or checks your heartbeat. A professional practice is built upon these personal relationships and presents a unique...