Corporate Business Taxation Monthly articles from March 2006

Corporate Business Taxation Monthly archives from March 2006

Multistate taxation.
March 1, 2006... Federal Provisions of S. 2152 and S. 2153, which are substantially similar, would promote the administration and collection of state sales and use taxes and would permit the implementation of the Streamlined Sales and Use Tax Agreement...

International taxation: IRS changes gain on recognition agreements.
March 1, 2006... The Treasury and the IRS have announced changes to Code Sec. 367 regulations on gain recognition agreements (GRAs). (1) As a result of these changes, a significant number of transactions may trigger existing GRAs. Background Code Sec....

IRS regulations limit code Sec. 7874 anti-inversion rule.
March 1, 2006... The American Jobs Creation Act of 2004 (2) added Code Sec. 7874 to the Internal Revenue Code to combat the perceived abuse of inversions of U.S. corporations into foreign corporations. On its face, the statute is overly broad, and, as a result,...

Taxation of compensation and benefits: the IRS determines which relocation arrangements result in compensation to the employee.
March 1, 2006... When employers transfer employees to other locations, they often try to make the move painless for each employee. One of the moving benefits that employers often offer is having a "relocation company" buy the employee's old house. The employer...

Issuing tax opinions in a new regulatory environment.
March 1, 2006... The primary objective of a tax advisor is to provide accurate and efficient tax advice that affords penalty protection to requesting taxpayers. In the past, tax advisors had a wide degree of discretion to conclude on various tax issues since...

Proposed regulations would curtail construction, engineering and architectural services.
March 1, 2006... The President and Congress enacted the Code Sec. 199 domestic production deduction to encourage U.S. production activities, including construction, engineering and architectural services. Code Sec. 199(c)(4)(A)(ii) specifies that "construction...

Tax briefing: President Bush signs legislation expanding hurricane relief, correcting 2004 Jobs Act glitches and more.
March 1, 2006... Four months after Hurricane Katrina devastated New Orleans and the Gulf Coast, Congress has approved a second massive tax relief bill to help individuals and businesses recover. On December 16, 2005, the Senate and the House passed, by...