IRS Says Smart Grid Investment Grants Under American Recovery and Reinvestment Act Program Non-Taxable

The Internal Revenue Service March 10 issued Revenue Procedure 2010-20 providing safe harbor treatment under tax code Section 118(a) for firms receiving grants for smart grid investment…

Government Officials Expect Net Operating Loss Carryback Guidance on Consolidated Groups Soon

The Internal Revenue Service and the Treasury Department expect to release soon guidance on a new net operating loss carryback tax code provision that will…

Senators Wyden, Gregg Introduce Tax Reform Bill That Would Eliminate Alternative Minimum Tax, Enact Reduced Flat Corporate Tax Rate

Sens. Ron Wyden (D-Ore.) and Judd Gregg (R-N.H.) Feb. 23 introduced comprehensive tax reform legislation (S. 3018) with provisions consolidating tax…

Limits on Scope of IRS’ Uncertain Tax Position Reporting Proposal Explored in PLI Webcast

Commissioner of Internal Revenue Douglas Shulman’s proposal for a tax schedule that would require large business taxpayers to proactively report their uncertain tax positions would not apply to taxes other than U.S. federal income taxes, nor would it affect passthrough entities, panelists said during a Feb. 18 Practising Law Institute webcast.

State Combined Reporting Regimes Pose Risks for Foreign Firms Without U.S. Presence

A foreign corporation that has no physical presence in the United States and no obligation to pay federal income taxes could nevertheless incur state tax liability in Massachusetts or Wisconsin under recently enacted combined reporting regimes, a panel of tax experts said Feb. 10.

ANALYSIS: Mandatory Combined Reporting a Challenge for State Taxpayers

A number of states have flirted with enacting combined reporting over the last two years for multinational businesses engaging in a unitary business. The most consistent reason states…

ANALYSIS: State Taxes in 2009: The Year in Review

KPMG’s review of state taxation in 2008 began with the quote, “It was the best of times, it was the worst of times …”; in contrast, 2009 generally was the worst of times—from start to finish…

Defense Contractors Avoided Taxes through Use of Foreign Affiliates, GAO Says

About one-third of the top 29 U.S. publicly traded defense contractors decreased their effective U.S. corporate tax rates in 2008 through the use of…

Obama Memo Blocks Delinquent Contractors from Receiving New Federal Contracts

President Obama Jan. 20 issued a presidential memorandum that directs the Office of Management and Budget, the Treasury Department, and other federal agencies to take steps to block contractors who are delinquent on their taxes from receiving…

IRS Finds No Foreign Base Company Sales Income from Transactions involving Bifurcated Manufacture of Products

The Internal Revenue Service in Private Letter Ruling 201002024, released Jan. 15, applied the tax rate disparity test in determining that…

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