Corporate Business Taxation Monthly articles from June 2007

Corporate Business Taxation Monthly archives from June 2007

Developments in multistate taxation.
June 1, 2007... Arizona When a multistate corporation invests its working capital in short-term instruments, only net gain from these short-term investments is included in the sales factor of the apportionment formula. Inclusion of short-term investment...

Proposed Reg. section 1.901-2(e)(5) and foreign tax credit.(International Taxation)
June 1, 2007... Proposed Reg. [section] 1.901-2(e)(5) denies the foreign tax credit for foreign income taxes incurred in connection with certain structured passive investment arrangements. The underlying principle is that a U.S. taxpayer cannot claim a foreign...

Determining qualified production activities income.
June 1, 2007... The ultimate determinant in ascertaining the domestic production deduction or the production incentive is to determine qualified production activities income (QPAI) under Code Sec. 199(c). All that remains is the W-2 limitation under Code Sec....

Is there a constitutional standard for UDITPA section 18 alternative apportionment?(Uniform Division of Income for Tax Purposes Act)
June 1, 2007... Increasingly, states are invoking alternative apportionment provisions to assert tax based on an apportionment formula that is not mandated by the state taxing statute. For example, multiple recent cases and rulings have addressed the use of...

Agribusinesses can claim production incentive benefits.
June 1, 2007... Agricultural businesses can claim benefits from the production incentive, the Code Sec. 199 domestic production deduction. (1) Three separate rules apply to agribusiness taxpayers: 1. Farmers, growers and other taxpayers can claim the Code...