Monthly Archives: October 2011

California — Corporate Income Tax — RIC Modernization Act of 2010—state conformity

L. 2011, A1423 (c. 490), effective 10/06/2011, conforms several provisions of the state income tax law to the federal Regulated Investment Company (RIC) Modernization Act of 2010 that, among others, (1) treats RICs similarly to individuals with regard to capital … Continue reading

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American Jobs Act introduced in Senate with millionaires’ surtax & deferred government contractor withholding

Late on October 5, Senate Majority Leader Harry Reid (D-NV) introduced S. 1660, the American Jobs Act of 2011. Reid made changes to the President’s original Jobs Act proposal (see ¶ 1975 ) by replacing the original pay-fors in the … Continue reading

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Act Public Before Going Public

How to manage tax accounting when preparing for an IPO BY DOUGLAS M. SAYUK, CPA, MATTHEW H. FRICKE AND R. DUGGER, ESQ., CPA OCTOBER 2011 After several years of increasing numbers of U.S. companies making initial public stock offerings, starting … Continue reading

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Supreme Court won’t review cases on capital contribution and economic substance

The Supreme Court has declined to review two Court of Appeals decisions, rendering the lower courts’ decisions final. In the AT&T case, the Court of Appeals for the Fifth Circuit, affirming the district court, held that universal service payments were … Continue reading

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Clifton Douglas pays its respects to Steve Jobs, a premier trailblazer in the high tech sector. He will be sorely missed. Our best wishes to his family, friends, and the employees of his remarkable company, Apple.

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No domestic production activities deduction in computing NOL for Sec. 965 election year

In Chief Counsel Advice (CCA), IRS has determined that a taxpayer is neither entitled to claim a Code Sec. 199 domestic production activities production (DPAD) nor a net operating loss (NOL) for a tax year in which it elected the … Continue reading

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