Monthly Archives: April 2011

IRS has released its twelfth required report providing details about the structure and activities of the advance pricing agreement (APA) program. The report says the number of APA applications during 2010 represented a record one-year high for the program. Ann. … Continue reading →

Two recent Congressional Research Service (CRS) Reports have examined a value-added tax (VAT), a broad-based consumption tax, as a possible fiscal solution to the high budget deficits and growing national debt. They discuss the feasibility and operation of implementing a … Continue reading →

In a revenue procedure, IRS has provided a safe harbor election allowing taxpayers to allocate 70% of the success-based fees paid in business acquisitions or reorganizations to activities that don’t facilitate the transaction and thus can be deducted currently. The … Continue reading →

Speaking before the Tax Executives Institute 61st Annual Mid-Year Meeting in Washington on April 5, Deputy Commissioner (International, LB&I Division) Michael Danilack touched on transfer pricing issues and articulated some of his concerns in resolving tax disputes with treaty partners … Continue reading →

IRS has issued final regs that reflect the reduction of the number of separate foreign tax credit limitation categories under Code Sec. 904(d) from eight to two by the American Jobs Creation Act of 2004 (AJCA), effective for tax years … Continue reading →

On April 5, Representative Paul Ryan (R-WI), chairman of the House Budget Committee, introduced his Chairman’s Mark proposing a new budget for fiscal year (FY) 2012 and setting forth appropriate budgetary levels for fiscal years 2013 through 2021. Ryan’s budget, … Continue reading →

In prepared remarks before the Tax Executives Institute (TEI) Midyear Meeting in Washington, D.C., on Apr. 4, Commissioner Douglas H. Shulman reported on various IRS strategies for issue resolution that he said are designed to be less time consuming and … Continue reading →

Arkansas has enacted an affiliate nexus and click-through nexus law. The new law creates a rebuttable presumption that an out-of-state seller is engaged in the business of selling tangible personal property or taxable services in Arkansas if an affiliate is … Continue reading →

Alabama Governor Robert Bentley announced that he had begun the administrative process of closing a business income tax loophole that allows certain types of multi-state companies to avoid paying taxes on income earned in Alabama. Specifically, the loophole in the … Continue reading →