Category Archives: Tax Alerts

What’s New: IRS Further Restricts “Million Dollar Cap” on Executive Compensation Potential Impact: Moderate. Recently issued proposed treasury regulations seek to broaden the scope of IRC §162(m) limits on federal income tax deductions related to officer’s compensation. Prior to the … Continue reading →

What’s New: Michigan Legislature Approves Repeal of the MBT – Corporate Income Tax Expected Beginning 2012 Potential Impact: High. On May 12, 2011, the Michigan Legislature approved the Governor’s plan to repeal the Michigan Business Tax (MBT) and replace it … Continue reading →

What’s New: IRS Authorizes Automatic 70% Deduction for Investment Banker Fees Potential Impact: High. On April 8, 2011, the IRS released Revenue Procedure 2011-29, which creates a safe harbor election allowing taxpayers to allocate 70% of the “success-based fees” paid … Continue reading →

What’s New: IRS Issues 382 Guidance for Pre-IPO Stock Valuations Potential Impact: Moderate. IRC § 382 provides specific limits on utilization of federal net operating losses (and state net operating losses where federal conformity exists) in the event of a … Continue reading →

What’s New: California Continues to Crack Down on Out-of-State Businesses with Stricter Nexus Requirements Potential Impact: Moderate. California-based companies can take some solace in the fact that the State is searching for additional tax revenues elsewhere. On the other hand, … Continue reading →

What’s New: Microsoft Decision Restricts Beneficial Impact of California’s Move Toward Mandatory Single Sales Factor Apportionment Potential Impact: Moderate. On February 17, 2011, the San Francisco Superior Court sided with the Franchise Tax Board ruling that Microsoft Corporation’s royalty income … Continue reading →

What’s New: Japan Plans to Cut Corporate Statutory Rate – U.S. Rate to be Highest in the World Potential Impact: High. On December 24, 2010, Japan’s Cabinet agreed to a budget including a cut in the corporate tax rate, effective … Continue reading →

What’s New: California Board of Equalization Adopts Nassco Formal Opinion – Enterprise Zone Credits May Offset AMT Potential Impact: Moderate. The California Board of Equalization (BOE), on November 17, 2010, voted in favor of adopting the formal opinion for Appeal … Continue reading →

What’s New: Corporate Filing Requirement for ISO and ESPP Stock Transfers Occurring After 2009 Potential Impact: Moderate. As amended by the 2006 Tax Relief and Health Care Act (TRHCA), IRC § 6039(a) now requires corporations to file an information return … Continue reading →

What’s New: California Proposition 24 Fails, but Higher Taxes Still on Horizon Potential Impact: High. Although California’s Budget Act of 2010 extended California’s net operating loss (“NOL”) suspension through tax years 2010 and 2011, California businesses have received some consolation … Continue reading →