Monthly Archives: October 2011

Washington Readopts Single Sales Factor Rules

The Department of Revenue has readopted WAC 458-20-19402 (Single factor receipts apportionment—Generally); 458-20-19403 (Single factor receipts apportionment—Royalties); and 458-20-19404 (Financial institutions—Income apportionment) on an emergency basis, effective October 3, 2011; taxpayers may use the rules to determine tax liability until … Continue reading

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New Jersey — Corporate Income Tax — Corporation business tax conformity to 2010 Tax Relief Act

The Division has released a memorandum discussing the federal Tax Relief Act of 2010 (TRA) and its impact on New Jersey corporation business tax (CBT). The TRA extended the bonus depreciation amount under the federal Small Business Jobs Act of … Continue reading

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California — Chief Counsel Rulings—“doing business” questions

The Franchise Tax Board (FTB) has clarified the situations when it will issue Chief Counsel Rulings in the light of the recent amendment of Cal. Rev. & Tax. Cd. § 23101 that added specific conditions for “doing business” in California … Continue reading

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FinCEN today issued Notice 2011-1 that extends the deadline until June 30, 2012, for the following individuals:

• An employee or officer of a regulated entity (as specified in the FBAR regulations) who has signature or other authority over and no financial interest in a foreign financial account of another entity more than 50 percent owned, directly … Continue reading

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Senate kills American Jobs Act, but portions of it may be considered separately

Late on October 11, the Senate by a vote of 50 to 49 failed to gain the necessary votes to invoke cloture (i.e. to cut off debate) on S. 1660, the American Jobs Act. The action effectively kills the bill, … Continue reading

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Tennessee Conformity with IRC net operating losses

Tennessee neither conforms to nor disallows the federal rules regarding the reduction of net operating losses (NOLs). The taxpayer’s Tennessee net operating loss for the year of discharge must be computed without taking into account any discharge of indebtedness income … Continue reading

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October Tax Alert – Issue 1

What’s New: November 1 Deadline Approaching for FBAR Filing Potential Impact: Moderate. A federal Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), must be filed by each U.S. person who has 1) a financial interest in … Continue reading

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California Single-sales factor formula election—new regulation

The Franchise Tax Board (FTB) has adopted Regulation § 25128.5 (Cal. Code Regs. § 25128.5, Tit. 18), effective October 22, 2011, which clarifies the single sales factor filing election newly available to multistate taxpayers that must apportion their business income … Continue reading

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New pipeline qualifies for first-year bonus depreciation

IRS has privately ruled that a new pipeline built to carry hydrogen gas to a customer’s facility was eligible for bonus depreciation, even though the new pipeline (1) was connected to a pre-existing pipeline network, and (2) was built under … Continue reading

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ARRIS Agrees to Acquire Clifton Douglas client BigBand Networks in all Cash Transaction.

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