Monthly Archives: July 2011

The New Jersey Supreme Court has affirmed lower court rulings that New Jersey’s (now-repealed) “Throw-Out Rule” (Rule) is not facially unconstitutional, but has construed the Rule narrowly, so as to limit the receipts that may be thrown out to untaxed … Continue reading →

IRS has announced that it is taking additional steps in order to improve its international operations. These steps consist of shifting the Advance Pricing Agreement and Mutual Agreement Programs to the same office under the Transfer Pricing Director in the … Continue reading →

The Court of Appeals for the First Circuit, affirming the Tax Court, has held that the cost of a covenant not to compete connected with the buyout of a 23% shareholder couldn’t be amortized over its one-year term because it … Continue reading →

Effective August 15, 2011, the Department of Revenue has updated regulations relating to combined reports, including apportionment of income, and updated regulatory references to reflect the single sales factor apportionment formula required for tax years beginning on or after January … Continue reading →

The District of Columbia Mayor has signed budget support legislation to provide funding for the 2012 budget. This legislation includes various tax increases, requires combined reporting, taxes most municipal bond interest, adopts an apportionment formula with a double-weighted sales factor, … Continue reading →

IRS has issued final regs that simplify the election to claim the reduced research credit under Code Sec. 280C(c)(3). The final regs also clarify that each member of a controlled group or trade or business which is treated as being … Continue reading →

The Hawaii Department of Taxation has issued announcements that summarize and clarify recently enacted legislation pertaining to IRC conformity. The deductions under Code Sec. 164(a)(3) (relating to state income taxes paid) and Code Sec. 165(b)(5) (relating to sales taxes paid … Continue reading →

The New York Legislature has extended the current New York City personal income tax, general corporation tax, and cigarette tax rates until 2015. The imposition of New York City sales and use tax on beauty and barbering services, and on … Continue reading →

As explained in this Practice Alert, carefully applying principles outlined in Notice 2010-50, 2010-27 IRB 12, could allow loss corporations to eliminate or alter the timing of an ownership change.

The Department of Revenue has issued a Tax Information Publication explaining recent changes to Florida’s corporate income tax and emergency excise tax law, which include: (1) additional adjustments for the special bonus depreciation and excess Code Sec. 179 expense that … Continue reading →