Monthly Archives: September 2010

Anti-offshoring tax bill introduced in Senate. Late on September 21, Senator Dick Durbin (D-IL) introduced S. 3816, the “Creating American Jobs and Ending Offshoring Act.” The Senate may vote on the measure during the week of September 27. This new … Continue reading →

Senate passes small business jobs bill containing tax breaks for large and small enterprises. On September 16, the Senate by a vote of 61-38 passed H.R. 5297, the Small Business Lending Funding Act, as amended. The tax title of this … Continue reading →

President proposes 100% expensing through 2011 plus liberalized, permanent research credit. During a September 8 speech in Cleveland, Ohio, the President, as expected, proposed to allow 100% expensing through 2011 and to liberalize and make permanent the research credit. The … Continue reading →

President Proposes Retroactive 100% Bonus Depreciation and Permanent Federal Research Credit. Potential Impact:  Neutral.  On September 8, 2010, President Obama will divulge a pro-business tax proposal aimed at stimulating the economy.  The proposal includes two primary initiatives to accomplish its … Continue reading →

Proposed reg would permit IRS to require reporting of uncertain tax positions (Preamble to Prop Reg 09/07/2010 ; Prop Reg § 1.6012-2). IRS has issued a proposed reg giving it the regulatory underpinning to require certain corporations to attach to … Continue reading →

President will propose that companies be allowed to more quickly write off 100% of their new investment in plants and equipment through 2011, along with extension of the federal R&D credit. The president is proposing that companies be allowed to … Continue reading →

SOI Bulletin examines returns of sole proprietorships & corps claiming foreign tax credits (IR 2010-94). IRS has announced the availability of the summer 2010 issue of the Statistics of Income (SOI) Bulletin, which features information on sole proprietorship returns filed … Continue reading →

Feature of the Week—International Tax Reform: Foreign Tax Credit “Reform”. The plea for substantive international tax reform has been heard from Congress, Treasury, MNEs, and commentators across a wide spectrum of fiscal views for many years. The effective tax rate … Continue reading →

“Check-the-box” election relief provided to foreign entities that mistake the number of their owners. In a Revenue Procedure, IRS has provided relief to foreign entities that make a “check-the-box” election either to be a partnership (under the reasonable but mistaken … Continue reading →

Presidential Advisory Report wades into tax reform debate with shopping list of proposals. Click here for the text of the President’s Economic Recovery Advisory Board (PERAB) Report on Tax Reform Options: Simplification, Compliance, and Corporate Taxation. The President’s Economic Recovery … Continue reading →