Corporate Business Taxation Monthly articles from February 2007

Corporate Business Taxation Monthly archives from February 2007

Developments in multistate taxation.
February 1, 2007... California The San Francisco County Superior Court has issued its "tentative" decision in Ventas Finance I, LLC. Similar to its earlier opinion in Northwest Energetic Services, LLC v. California Franchise Tax Board, No. CGC-05-437721 [Cal....

The Treasury fleshes out Code Sec. 362(e)(2).(assets and stock transfer)
February 1, 2007... On October 20, 2006, the IRS issued proposed I regulations that provide guidance under Code Sec. 362(e)(2) (hereinafter referred to as the "Proposed Code Sec. 362(e)(2) Regulations")(1) These proposed regulations provide direction for...

Ecuador adopts detailed transfer pricing documentation requirements.
February 1, 2007... The Director General of Ecuador's income tax division, Elsa de Mena, issued transfer pricing regulations on December 30, 2005. Article 1 of these regulations imposes documentation requirements on Ecuadorian multinational taxpayers. The...

State tax considerations for equity-based compensation.
February 1, 2007... The use of equity-based compensation (e.g., stock options and restricted stock) is widespread by public corporations as a means to attract and retain employees. Few employers consider the state tax burdens of equity-based compensation. Without...

Temporary computer software regulations limit production incentive benefits.
February 1, 2007... The temporary computer software regulations, Temporary Reg. [section] 1.199-3T(i)(6), narrow the production incentive as compared with the statute, Code Sec. 199(c)(5)(B). These software regulations arbitrarily categorize many computer software...