Corporate Business Taxation Monthly articles from May 2006

Corporate Business Taxation Monthly archives from May 2006

Developments in multistate taxation.
May 1, 2006... Federal Provisions of proposed bill H.R. 4845 would establish physical presence as the nexus standard for all state "business activity taxes." Business activity taxes would include the following taxes: * Net income tax * A tax...

Regulations provide late election relief under the PFIC rules.(passive foreign investment company)
May 1, 2006... New Temporary Reg. [section] 1.1297-3T(e) and 1.1298-3T(e) contain guidelines for untimely "purging" elections. These guidelines would eliminate passive foreign investment company (PFIC) taint on certain shares of foreign corporations. The new...

Basis, boot and foreign mergers.
May 1, 2006... The IRS and the Treasury promulgated final regulations under Code Sec. 358 ("Final Code Sec. 358 Regulations") on January 23, 2006. (1) The Final Code Sec. 358 Regulations address the determination of the basis of stock or securities received...

Passthrough entities impact the domestic production deduction.
May 1, 2006... The proposed Reg. [section] 1.199-5 regulations address the domestic production deduction in the context of passthrough entities. The proposed Reg. [section] 1.199-5 passthrough regulations are delineated as follows: * Partnerships,...

Claiming the production incentive for timber, minerals and oil and gas activities.
May 1, 2006... The Code Sec. 199 domestic production deduction provisions specifically enumerate nine specific production categories: * Tangible personal property, pursuant to Code Sec. 199(c)(4)(A)(i)(I) and Code Sec. 199(c)(5)(A) * Computer...