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Canadian income trusts and income deposit securities: the U.S. tax perspective.
January 1, 2007... Income Trusts ("IT"), established Canadian finance vehicles, and Income Deposit Securities ("IDS"), their U.S. modified and Canadian re-imported variations, have been employed in a number of recent acquisitions of U.S.--situs businesses. (1) As...
Liability claims impact unclaimed property. (California)
January 1, 2007... The California Court of Appeals addressed unclaimed property issues. In the first case to address the issue, the California Court of Appeals in Harris v. Verizon Communications (1) held that the indemnification provision of the California...
Automatic 401(k) enrollment and default investment elections.
January 1, 2007... Congress enacted the Pension Protection Act of 2006 (PPA) (1) primarily to shore up the funding of defined benefit plans and to avert the prospect of an expensive bailout of the government-run Pension Benefit Guaranty Corporation. In addition,...
Understanding the IRS appeals arbitration program.
January 1, 2007... The IRS issued Rev. Proc. 2006-44 on October 18, 2006, formally establishing its Appeals arbitration program? The Appeals arbitration program applies only in limited situations, and only to a limited class of taxpayers. Taxpayers and their...