U.S. Law Watch » Corporate Taxes http://www.uslawwatch.com U.S. Legal & Regulatory Headlines Thu, 26 Jan 2012 18:07:29 +0000 en hourly 1 http://wordpress.org/?v=3.3.1 Newly Codified Economic Substance Doctrine Could Mean More IRS Challenges, Practitioners Say http://www.uslawwatch.com/2010/05/26/tax/newly-codified-economic-substance-doctrine-irs-challenges-practitioners/ http://www.uslawwatch.com/2010/05/26/tax/newly-codified-economic-substance-doctrine-irs-challenges-practitioners/#comments Wed, 26 May 2010 10:53:58 +0000 admin http://www.uslawwatch.com/?p=2187

The newly codified economic substance doctrine may clear the way for Internal Revenue Service challenges to a broader range of transactions than before, tax practitioners said May 20.

The statutory change may signal that “IRS is going to start to attack other areas beyond traditional shelters,” Sam Kaywood, Alston & Bird LLP, Atlanta, said.

Kaywood, who moderated a panel on the issue at the Atlanta Region International Fiscal Association, said that in the international area, the government could use the codified doctrine to address transfer pricing transactions and deals involving deferral and the foreign tax credit, among others.

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]]> http://www.uslawwatch.com/2010/05/26/tax/newly-codified-economic-substance-doctrine-irs-challenges-practitioners/feed/ 0 Business Groups Oppose Tax Extenders Bill, Put Pressure on Democrats on Eve of House Vote http://www.uslawwatch.com/2010/05/25/tax/business-groups-oppose-tax-extenders-bill-put-pressure-democrats-eve-house-vote/ http://www.uslawwatch.com/2010/05/25/tax/business-groups-oppose-tax-extenders-bill-put-pressure-democrats-eve-house-vote/#comments Tue, 25 May 2010 14:30:12 +0000 admin http://www.uslawwatch.com/?p=2170

Business organizations May 24 lashed out against congressional Democrats’ tax extenders and jobs bill (H.R. 4213) set for House floor consideration, saying that its permanent tax increases on firms with foreign income will be harmful to employers…

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]]> http://www.uslawwatch.com/2010/05/25/tax/business-groups-oppose-tax-extenders-bill-put-pressure-democrats-eve-house-vote/feed/ 0 IRS, Treasury Working on Consolidated Groups Guidance Under Net Operating Loss Carryback http://www.uslawwatch.com/2010/04/30/tax/irs-treasury-working-consolidated-groups-guidance-net-operating-loss-carryback/ http://www.uslawwatch.com/2010/04/30/tax/irs-treasury-working-consolidated-groups-guidance-net-operating-loss-carryback/#comments Fri, 30 Apr 2010 16:35:12 +0000 admin http://www.uslawwatch.com/?p=1847

The Internal Revenue Service and Treasury Department soon will issue guidance to address issues for consolidated groups raised by the recently enacted five-year net operating loss carryback, a senior Treasury official said April 29…

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]]> http://www.uslawwatch.com/2010/04/30/tax/irs-treasury-working-consolidated-groups-guidance-net-operating-loss-carryback/feed/ 0 Manufacturing Deduction Impacted in Years New Net Operating Loss Carryback Used, IRS Officials Say http://www.uslawwatch.com/2010/04/28/tax/manufacturing-deduction-impacted-years-net-operating-loss-carryback-irs-officials/ http://www.uslawwatch.com/2010/04/28/tax/manufacturing-deduction-impacted-years-net-operating-loss-carryback-irs-officials/#comments Wed, 28 Apr 2010 11:05:28 +0000 admin http://www.uslawwatch.com/?p=1812

Taxpayers who claim the newly enacted five-year net operating loss carryback should be careful about the impact if they carry back their losses to any year in which they also claimed the manufacturing deduction under…

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]]> http://www.uslawwatch.com/2010/04/28/tax/manufacturing-deduction-impacted-years-net-operating-loss-carryback-irs-officials/feed/ 0 BNA INSIGHTS: Tax-Based Leasing, Tax Credits, and Economic Substance http://www.uslawwatch.com/2010/04/22/tax/bna-insights-taxbased-leasing-tax-credits-economic-substance/ http://www.uslawwatch.com/2010/04/22/tax/bna-insights-taxbased-leasing-tax-credits-economic-substance/#comments Thu, 22 Apr 2010 13:42:53 +0000 admin http://www.uslawwatch.com/?p=1737

Leasing has traditionally been a way for developers and other users of equipment to indirectly access tax credits and other government incentives for capital investment (such as accelerated depreciation) when they did not otherwise have the tax capacity to benefit from such incentives on a current basis.
In a leveraged lease or other tax-based lease financing, an investor with adequate tax capacity purchases the capital asset and leases it to the developer or other end user at rents that reflect, in part, the tax benefits available to the lessor. Thus, the developer or other end user (in the role of the lessee) receives, indirectly, at least part of the benefit of tax incentives.

This general model of indirect tax benefit transfers via leasing has been…

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]]> http://www.uslawwatch.com/2010/04/22/tax/bna-insights-taxbased-leasing-tax-credits-economic-substance/feed/ 0 IRS Uncertain Positions Documents Answer Some Questions, Leave Others, Practitioners Say http://www.uslawwatch.com/2010/04/21/tax/irs-uncertain-positions-documents-answer-questions-leave-practitioners/ http://www.uslawwatch.com/2010/04/21/tax/irs-uncertain-positions-documents-answer-questions-leave-practitioners/#comments Wed, 21 Apr 2010 10:40:08 +0000 admin http://www.uslawwatch.com/?p=1724

The draft schedule and instructions that taxpayers would use to report uncertain tax positions, unveiled by the Internal Revenue Service April 19, are administratively helpful and well thought out—but concerns remain about the use of the information and the scope and breadth of the proposal itself, practitioners told BNA in interviews April 20.

The documents, issued under…

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]]> http://www.uslawwatch.com/2010/04/21/tax/irs-uncertain-positions-documents-answer-questions-leave-practitioners/feed/ 0 IRS Corporate Audits Declining, Research Group Says; Agency Disagrees with Analysis http://www.uslawwatch.com/2010/04/13/tax/irs-corporate-audits-declining-research-group-agency-disagrees-analysis/ http://www.uslawwatch.com/2010/04/13/tax/irs-corporate-audits-declining-research-group-agency-disagrees-analysis/#comments Tue, 13 Apr 2010 10:55:58 +0000 admin http://www.uslawwatch.com/?p=1627

The Internal Revenue Service’s audit efforts aimed at the nation’s largest corporate taxpayers have declined since 2005 and are now “at an all-time low,” according to a report released April 12 by the Transactional Records Access Clearinghouse, a research organization based at…

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]]> http://www.uslawwatch.com/2010/04/13/tax/irs-corporate-audits-declining-research-group-agency-disagrees-analysis/feed/ 0 Obama Signs Measure Creating $13 Billion in Tax Breaks for Businesses Hiring Workers http://www.uslawwatch.com/2010/03/19/tax/obama-signs-measure-creating-13-billion-tax-breaks-businesses-hiring-workers/ http://www.uslawwatch.com/2010/03/19/tax/obama-signs-measure-creating-13-billion-tax-breaks-businesses-hiring-workers/#comments Fri, 19 Mar 2010 10:40:34 +0000 admin http://www.uslawwatch.com/?p=1377

President Obama signed the HIRE Act (Pub. L. No. 111-92) into law March 18, creating tax breaks for businesses hiring new workers and extending higher expensing limits for small businesses that…

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]]> http://www.uslawwatch.com/2010/03/19/tax/obama-signs-measure-creating-13-billion-tax-breaks-businesses-hiring-workers/feed/ 0 ANALYSIS: Who Needs ‘Customers’? The Real Import (or Export) of IRS Announcement 2010-9 on ‘Uncertain Tax Positions’ http://www.uslawwatch.com/2010/03/18/tax/analysis-customers-real-import-export-irs-announcement-20109-uncertain-tax-positions/ http://www.uslawwatch.com/2010/03/18/tax/analysis-customers-real-import-export-irs-announcement-20109-uncertain-tax-positions/#comments Thu, 18 Mar 2010 10:57:07 +0000 admin http://www.uslawwatch.com/?p=1363

If anything explodes the fiction that the U.S. Internal Revenue Service and the taxpayer—particularly the corporate taxpayer—are in a constructive partnership or friendly “customer” relationship to ensure only that the “correct” amount of tax is collected, it is the recent bombshell by IRS contained in Announcement 2010-9…

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]]> http://www.uslawwatch.com/2010/03/18/tax/analysis-customers-real-import-export-irs-announcement-20109-uncertain-tax-positions/feed/ 0 Proposed Payment Card Reporting Rules Would Put U.S. Payers at Competitive Disadvantage, Witnesses Tell IRS http://www.uslawwatch.com/2010/03/16/tax/proposed-payment-card-reporting-rules-put-payers-competitive-disadvantage-witnesses-irs/ http://www.uslawwatch.com/2010/03/16/tax/proposed-payment-card-reporting-rules-put-payers-competitive-disadvantage-witnesses-irs/#comments Tue, 16 Mar 2010 11:40:36 +0000 admin http://www.uslawwatch.com/?p=1339

Witnesses at a March 15 Internal Revenue Service hearing on payments made to settle payment card and third-party network transactions focused on the foreign reporting requirements of the proposed…

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