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Not all three-party transactions are created equal.
May 1, 2003... In the simplest of terms, a three-party transaction is comprised of a target corporation ("Target"); three parties who are either sellers, buyers, or part sellers and part buyers; and an accompanying tax liability that is triggered on the sale...
New IRS rules for split-dollar life insurance arrangements.
May 1, 2003... The IRS issued proposed regulations in the summer of 2002 on the taxation of split-dollar life insurance arrangements (hereinafter referred to as "split-dollar"). These rules present a completely new taxation scheme for split-dollar. More...
Taxation of compensation and benefits.
May 1, 2003... The Tax Court has ruled that medical benefits for retired employees may be fully funded in a single deductible payment. (1)
Background
On January 1, 1930, Norwest Corporation (Norwest) established a self-insured medical plan to provide...
Temporary and proposed regulations issued on "A" reorganizations.
May 1, 2003... Temporary and Proposed Regulations Issued on "A" Reorganizations
The IRS and the Treasury recently published new temporary regulations (1) and proposed regulations (2) providing guidance concerning the definition of the terms "statutory...
Multistate taxation.(developments in Indiana, Pennsylvania, North Dakota, and Massachusetts)
May 1, 2003... This month's column addresses significant state income and franchise tax developments in Indiana, Pennsylvania, North Dakota, and Massachusetts. The Indiana Department of Revenue determined that gain from a stock sale, litigation settlements,...
Tax accounting.(capitalization of intangibles costs )
May 1, 2003... This and next month's columns explore one of several contentious issues addressed in the proposed regulations on the capitalization of intangibles costs issued last December. These regulations represent the latest stage in ongoing efforts by...