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Corporate Business Taxation Monthly articles from July 2007
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Corporate Business Taxation Monthly archives from July 2007
Cross-border related-party intangibles transfers.
July 1, 2007... Cross-border related-party intangibles transfers became the issue in AM-2007-007. (1) The associate chief counsel (international) provided generic legal advice to the Large and Mid-Sized Business operating division of the IRS. The associate...
Analyzing deferred compensation arrangements under the section 409A final regulations: a six-step analytic process: this is the first installment of Stewart Reifler's six-step analysis. We will present parts III and IV in the August issue, and conclude with parts V and VI in the September issue.(part 1)
July 1, 2007... On April 10, 2007, the United States Treasury Department ("Treasury") issued final regulations (the "Final Regs") under Internal Revenue Code Section 409A ("Code Sec. 409A"). (1) Congress enacted Code Sec. 409A in October 2004 to strictly...
Final regs amplify the expanded affiliated group production incentive.
July 1, 2007... The Treasury Department and IRS, in promulgating the Code Sec. 199 domestic production deduction final regulations, added an extensive number of examples to illustrate the [section] 1.199-7 Expanded Affiliated Group (EAG) provisions. (1) As tax...