Corporate Business Taxation Monthly articles from June 2002

Corporate Business Taxation Monthly archives from June 2002

Notes from the editors.
June 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...

Developing the initial standard transfer pricing information document request. (IRS rules regarding transfer pricing)
June 1, 2002... Audits have been decreasing as a percentage of taxpayer returns during the past few years because of IRS staffing shortages. These shortages may have led to a kinder, gentler IRS, but have severely challenged the veracity of America's taxing...

The limited liability company versus the S corporation.
June 1, 2002... Owners and investors should carefully choose the type of entity through which they will operate or invest, as applicable, in any new business venture. This choice involves several options that vary from the simple sole proprietorship to much...

Modifying transfer pricing procedures. (IRS and Treasury Department to revise transfer pricing regulations)
June 1, 2002... The Treasury and the IRS asked Robert Feinschreiber and Margaret Kent to put forth their suggestions to correct defects in the U.S. transfer pricing system. This process encompasses documentation, examination procedures, and transfer pricing...

Shareholder-owned goodwill in certain corporate transactions.
June 1, 2002... Corporate liquidations cause two levels of tax to be imposed, a tax on the corporation and a tax on the shareholder. This has been the state of the law since the legislative repeal of the General Utilities (1) doctrine. When a corporation...

Taxation of compensation and benefits. (not subject to Federal Insurance Contributions Act in CSX Corp. v. U.S.) (Brief Article)
June 1, 2002... The U.S. Federal Court of Claims has held that payments to workers who were involuntarily laid off during a reduction in force (RIF) were supplemental unemployment compensation benefits that were not subject to FICA. The company was granted a...

Tax accounting. (IRS to review procedures for changes of accounting methods)
June 1, 2002... This month's column examines two revenue procedures issued by the IRS in March that address changes of accounting methods. In Revenue Procedure 2002-18, (1) the IRS has for the first time promulgated specific rules covering "involuntary"...

New consolidated return loss disallowance regulations issued.
June 1, 2002... NEW CONSOLIDATED RETURN LOSS DISALLOWANCE REGULATIONS ISSUED The rule governing a consolidated group's ability to claim a loss of the disposition of the stock of a member of the group--the Loss Disallowance Rule of Treas. Reg. Section...

Multistate taxation. (sales tax)
June 1, 2002... This month's column discusses recent developments in sales taxation of the states. The Indiana Tax Court ruled on the assignment of the right to a sales tax deduction. The Massachusetts Appellate Tax Board upheld an assessment against...

International taxation. (potential IRS changes to antitrust and transfer pricing regulations) (Brief Article)
June 1, 2002... Antitrust issues are now becoming more significant for Section 482 transfer pricing purposes than antitrust issues have been in the past. These antitrust issues become important when the taxpayer or the IRS undertakes a comparability analysis...