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Corporate Business Taxation Monthly articles from July 2006
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Corporate Business Taxation Monthly archives from July 2006
An IRS notice highlights uncertain consequences of cross licensing agreements.
July 1, 2006... The Treasury and the IRS have requested information regarding cross license agreements (CLA) in connection with a project to provide guidance on the tax consequences of participating in a CLA. (1)
Background
The typical CLA is an...
The new federal lighting tax deduction.
July 1, 2006... The Energy Tax Incentives Act of 2005 (1) provides incentives for "building systems," which include lighting, HVAC and building envelope. Of the three building systems, lighting has seen the most activity as a result of the new law, making the...
Claiming deductions for foreign related persons.
July 1, 2006... In two recent cases, Swallows Holding, Ltd. (1) and Square D Co., (2) multinational enterprises have challenged the validity of certain U.S. tax regulations that, inter alia, may be viewed as having discriminatory effects against non-U.S....
Applying the DISC marginal costing rules.(domestic international sales corporation)
July 1, 2006... Marginal costing is a valued transfer pricing methodology, a profit-shifting opportunity for a Domestic International Sales Corporation (DISC) and its related suppliers/This marginal costing methodology shifts income from the high-taxed DISC's...