Monthly Archives: January 2012

IRS provides last-minute transitional relief from Sec. 6045B reporting requirements (Notice 2012-11, 2012-5 IRB)

In a notice, IRS has provided last-minute transitional relief from the Code Sec. 6045B reporting requirements applicable to issuers of stock with respect to organizational actions that affect the basis of the stock. An issuer’s requirement to file and furnish … Continue reading

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Clifton Douglas wishes everyone a happy and safe Martin Luther King, Jr. holiday weekend!

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January Tax Alert – Issue 3

What’s New: Deadline to File Another New Tax Form is Rapidly Approaching – Due January 17, 2012 Potential Impact: Moderate. Corporations (among other entities) are now required to file IRS Form 8937, Report of Organizational Actions Affecting Basis of Securities, … Continue reading

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PLI to hold 2012 program: “International Tax Issues 2012”

The Practising Law Institute (PLI) will hold its program: “International Tax Issues 2012” at the PLI New York Center, 810 Seventh Avenue at 53rd Street (21st floor), New York, New York 10019 on Feb. 2, 2012.

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January Tax Alert – Issue 2

What’s New: IRS Guidance Supports Opportunity to Adjust Closed Year NOL for Open Year Utilization Potential Impact: Moderate. The IRS recently released a Technical Advice Memorandum (CCA 201151021) that, although not citable precedent, provides some support for taxpayers to adjust … Continue reading

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IRS releases Form 8937 to report organizational actions affecting security holders’ basis

IRS has released on its website Form 8937, Report of Organizational Actions Affecting Basis, and its Instructions. The Instructions include details on who must file the form and how certain entities can otherwise satisfy their organizational action reporting obligations.

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California — Corporate Income Tax — 2011 FTB publications issued

The Franchise Tax Board has reissued its Informational Publications to reflect recent legislation (including single-sales factor apportionment and new economic nexus laws) and other changes that take effect starting with the 2011 tax year: Pub. 933C, Bankruptcy Service and Contact … Continue reading

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California Supreme Court Denies Review of Apple Reporting Decision

The California Supreme Court has denied review of a Court of Appeal decision that rejected a multinational corporation’s (Apple) claim that it was improperly subjected to double taxation when it switched from worldwide combined reporting to water’s-edge combined reporting in … Continue reading

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New Jersey enacts new corporate income tax credits to promote job creation

Governor Chris Christie has signed legislation that creates the GrowNJ Assistance program, which provides tax credits to companies moving to or growing in New Jersey based on capital investment and job creation or retention. This program is administered by the … Continue reading

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IRS reopens offshore voluntary disclosure program with some changes

IRS has announced that it has reopened the offshore voluntary disclosure program (OVDP) with some changes. It also noted that it has collected over $4.4 billion under the two prior programs. IR 2012-5.

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