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Practical and policy considerations in corporate inversion transactions.
September 1, 2002... INTRODUCTION
Perhaps the hottest topic in U.S. tax circles over the past few months has been the growing number of U.S. corporations completing or announcing transactions that move their domicile offshore through some form of corporate...
Recovering administrative and litigation expenses from the government.
September 1, 2002... Taxpayers that prevail against the Internal Revenue Service (IRS) may be able to recover administrative and litigation expenses. Section 7430 of the Internal Revenue Code (Code) provides for the recovery of reasonable administrative and...
Taxation of compensation and benefits.(health reimbursement accounts)
September 1, 2002... There has been increased interest recently in the use of reimbursement accounts in the design of new health care delivery models, such as so-called defined contribution health plans or consumer-driven health plans. Forms of cafeteria-plan-based...
Corporate reorganizations.(loss disallowance rule)
September 1, 2002... NEW LOSS DISALLOWANCE REGULATIONS AMENDED
Earlier this year, the IRS and the Treasury Department issued temporary and proposed regulations governing a consolidated group's ability to claim a loss on the disposition of the stock of a member...
Multistate taxation.(tax developments in New Jersey, North Carolina, and New York)
September 1, 2002... The tax landscape for multistate businesses continues to develop as many states struggle to solve budgetary crises and interpret legislative changes enacted to raise revenue. This month's column addresses significant state tax developments in...
International taxation.
September 1, 2002... The premerger notification process in the United States is 25 years old. The Hart Scott Rodino (HSR) Act provides the Federal Trade Commission (FTC) and the Department of Justice (DoJ) with the wherewithal to review mergers and acquisitions...