Author Archives: cdwp

Treasury and IRS have made progress on prioritizing and issuing guidance, working to meet varied deadlines such as those imposed by the Foreign Account Tax Compliance Act (FATCA) and the expiring proposed anti-inversion regulations, officials said May 11.

The Tax Court has held that a corporate taxpayer’s investment in a foreign corporation was more appropriately characterized as debt, rather than equity, thereby eliminating claimed foreign tax credits. In addition, it held that the taxpayer was not entitled to … Continue reading →

On May 11, 2012, Arizona Governor Jan Brewer signed business tax legislation that makes changes to existing corporate, personal and premium tax credits and features increased capital gains tax deductions. (L. 2012, H2815, generally effective 08/02/2012 and as provided below.) … Continue reading →

During its review of Schedule UTP (Uncertain Tax Position Statement) filed by taxpayers for the 2010 year, IRS has discovered that descriptions of some disclosed tax positions were more “concise” than they should have been. A new page on its … Continue reading →

In February of this year, IRS issued proposed regs and a Joint Statement regarding the implementation of the Foreign Account Tax Compliance Act (FATCA). Many comments were received in response to the regs, several of which are explored below. Common … Continue reading →

IRS has issued temporary and proposed regs on the treatment of upfront payments made under certain notional principal contracts (NPCs) for federal income tax purposes. They provide that certain obligations of U.S. persons arising from upfront payments made by controlled … Continue reading →

Some practitioners have stated that FATCA and the extensive Proposed Regulations thereunder could be a factor in getting more countries to sign automatic information exchange agreements with the United States.

The Department of Revenue has issued a Tax Information Publication that summarizes the 2012 legislative changes affecting the Florida corporate income tax. Recent legislation amends Florida law to adopt the Internal Revenue Code retroactively to January 1, 2012 so that … Continue reading →

On May 8, the Senate voted 52 to 45, 1 present, against the motion to invoke cloture (i.e., cut off debate) on the motion to proceed to S. 2343, the “Stop the Student Loan Interest Rate Hike Act of 2012.” … Continue reading →