Monthly Archives: September 2011

Montana — Corporate Income Tax — Net operating losses, apportionment, and water’s edge-elections

The Montana Department of Revenue has adopted and amended numerous corporate income tax rules, effective September 23, 2011, including: (1) a new rule designed to simplify the net operating loss (NOL) calculation for multinational taxpayers for tax periods in which … Continue reading

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President sends detailed jobs growth and long-term deficit reduction proposal to Congress

On September 19, the President submitted to Congress his 80-page blueprint for jobs growth and long-term deficit reduction. The plan combines short-term, mainly payroll-tax-oriented jobs stimulus provisions, overhauls to major entitlement programs, and a tax reform package featuring tax increases … Continue reading

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IRS issues new guidance on use of Schedule UTP in CAP program

IRS’s Large Business and International (LB&I) division has issued guidance on the use of Schedule UTP, Uncertain Tax Position Statement, as part of the Compliance Assurance Process (CAP). The guidance applies to CAP returns filed for the 2010 tax year … Continue reading

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Several states are considering their own uncertain tax position reporting process

[BNA Daily Tax Report, August 31, 2011, page H-2; Lowell & Martin: U.S. International Taxation: Practice and Procedure ¶ 14.07 ].

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Transfer Pricing Regimes in 66 Countries

Transfer pricing regimes, complete with documentation requirements and often draconic penalties for not timely preparing or submitting the documentation in a timely manner, have spread around the world. At last count, there are 66 countries, with new regimes in Qatar … Continue reading

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Obama’s Jobs Act Likely to Encounter Rough Times Ahead

“Democrats last night lost special elections in New York and Nevada, and Obama’s approval rating didn’t help; a new poll shows that 51% of Americans don’t believe his jobs plan will help lower the unemployment rate; and a congressional hearing … Continue reading

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Administration submits “American Jobs Act of 2011” to Congress

Read the Bill Text Here http://blogs.orlandosentinel.com/news_politics/files/2011/09/American_Jobs_Act_-_final.pdf

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Good morning, Clifton Douglas followers! We hope everyone had a great weekend and are close to meeting September 15th deadlines

At the forefront of today’s news, President Obama has unveiled the “American Jobs Act,” which is a proposal to stimulate the economy. The Act includes tax incentives for businesses as follows: 1) Extend 100% expensing—the opportunity to “take an immediate … Continue reading

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