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Notes from the editors.
May 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...
Proposals for revising the transfer pricing audit structure.
May 1, 2002... The IRS is now in the process of modifying its transfer pricing procedures, as the 1993 regulations have proven to be deficient in a number of respects, including documentation, examination procedures, and methodologies. These modifications...
The proposed research tax credit regulations.
May 1, 2002... Congress enacted the research and development credit (R&D credit or the research credit) in 1981 as an incentive to encourage more research activities. Many U.S. companies were reluctant to bear the significant costs incurred in initiating or...
Taxation of compensation and benefits.(golden parachutes)
May 1, 2002... The IRS and Department of Treasury have released proposed regulations on the golden parachute rules under Section 280G. These proposed regulations provide changes to prior regulations and clarify issues that arise during the 280G analysis. 67...
Tax accounting.
May 1, 2002... This month's column explores a spate of recent IRS administrative releases on tax accounting issues:
* An IRS "advance notice of proposed rulemaking" provides a sneak preview of the forthcoming intangibles capitalization regulations.
...
Consolidated return loss disallowance rule revisited.
May 1, 2002... CONSOLIDATED RETURN LOSS DISALLOWANCE RULE REVISITED
In Notice 2002-11 (1) the Treasury Department and the IRS announced that the government would not appeal the decision of the Federal Circuit Court of Appeals (the Federal Circuit Court)...
Multistate taxation.
May 1, 2002... State tax developments continued through the first quarter of 2002. Taxing authorities, including the Kansas Supreme Court and the Illinois Department of Revenue Administrative Hearings Division, handed down decisions of interest to multistate...
International taxation.
May 1, 2002... LOSS FROM BASIS SHIFTING TRANSACTION DISALLOWED
In a Field Service Advice, the IRS National Office has concluded that an individual taxpayer may not deduct a stock loss generated in a basis-shifting transaction. The IRS National Office...