Corporate Business Taxation Monthly articles from July 2002

Corporate Business Taxation Monthly archives from July 2002

Notes from the editors.
July 1, 2002... Corporate Business Taxation Monthly is the only monthly publication specifically committed to meeting the needs of corporate tax executives and their professional advisors. As such, Corporate Business Taxation Monthly continues to provide...

Value chain analysis: the pharmaceutical industry example.
July 1, 2002... INTRODUCTION In the U.S. Department of the Treasury, the Commissioner of the Internal Revenue Service, under the Internal Revenue Code, Section 482, has been delegated to allocate gross income among businesses to prevent evasion of taxes...

The Pennsylvania manufacturing exemption and the PPG case. (tax exemption, PPG Industries v. Commonwealth)
July 1, 2002... The Pennsylvania Supreme Court held in PPG Industries, Inc. v. Commonwealth that Pennsylvania's manufacturing exemption was discriminatory and in violation of the Commerce Clause of the United States Constitution. The Court ordered that the...

Taxpayers win manufacturers' investment credit appeals in California.
July 1, 2002... Taxpayers won the first two manufacturers investment credit (MIC) cases before the California State Board of Equalization (SBE). Both cases challenged the actions of the Franchise Tax: Board (FTB), which administers the franchise and income...

Taxation of compensation and benefits. (IRS ruling on reverse vesting) (Brief Article)
July 1, 2002... The IRS has recently ruled on the application of Section 83 when shareholder-employees agree to exchange their fully vested shares for nonvested shares (reverse vested shares). The focus of the ruling is actually the interaction between Section...

Tax accounting. (interest deduction in bankruptcy)
July 1, 2002... This month's column discusses a Michigan bankruptcy court's decision which illustrates several aspects of the "all events" test that governs accrual taxpayers' deductions. One key holding was that the taxpayer was entitled to deduct all the...

New regulatory guidance under section 355(e). (IRC section 355)
July 1, 2002... NEW REGULATORY GUIDANCE UNDER SECTION 355(e) In recent years, there has been a flurry of regulatory activity in the context of Section 355(e). The regulatory projects have primarily interpreted the scope of the "a plan (or series of related...

Multistate taxation.
July 1, 2002... Developments in the arena of state taxation continued through the second quarter of 2002. Taxing authorities including the Kansas and Missouri Supreme Courts and the Minnesota Tax Court handed down decisions of interest to multistate taxpayers....

International taxation.
July 1, 2002... On March 29, 2002, the Internal Revenue Service issued the Advance Pricing Agreement (APA) Program's third annual report on APA operations (IRS Announcement 2002-40). (1) APA PROGRAM STATISTICS In 2001, the APA expanded its staff from...