Practical US/Domestic Tax Strategies

Only Practical US/Domestic Tax Strategies delivers expert insight into the proven strategies your colleagues are using to minimize tax liability. Every month, Strategies delves into how domestic tax and regulatory developments will affect your organization ... and what you can do about it right now.
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Download PDF of July 2010 Issue of Practical US/Domestic Tax Strategies
31 Aug 2010

In This Edition

Planning Perspective
Special Distressed Debt Tax Election Affects Future M&A Tax Planning
By Wayne R. Strasbaugh (Ballard Spahr LLP) p. 2

Federal Tax
IRS Will Scrutinize Fringe Benefits During Employment Tax Audits
By Eileen J. O’Connor and Clare Stoudt (Pillsbury Winthrop Shaw Pittman LLP) p. 3

FASB Proposes Expanded Disclosures Regarding Loss Contingencies
By Robert J. Malionek, Kim Marie K. Boylan and Adam J. Goldberg (Latham & Watkins LLP) p. 4

State and Local Taxes
Illinois--Illinois Budget and Regulatory Changes: Including Tax Amnesty Program, R&D and Other Tax Credits
By Joe Carr and Nick Boegel (BDO USA, LLP) p. 8

Massachusetts--Massachusetts Tax Reforms Under the Economic Development Act
By Richard W. Giuliani, Julie Hogan Rodgers and Ciara R. M. Brogan (WilmerHale) p. 12

New York/New Jersey--New York and New Jersey Propose Significant Unclaimed Property Amendments
By Diann L. Smith and Mark W. Yopp (Sutherland Asbill & Brennan LLP) p. 13

Pennsylvania--Pennsylvania Supreme Court Reaffirms Taxability of Canned Software
By Lance S. Jacobs (Pepper Hamilton LLP) p. 15

Highlights

Section 108(i) Regulations Trigger Income in Some M&A Transactions
The IRS released temporary regulations in August that clarify how and when income deferred under Section 108(i) must be recognized. Planners of corporate acquisitions will want to inquire about the Section 108(i) election history of potential acquisition targets. Page 2

Time for an Internal Audit to Prepare for Visit by IRS?
The IRS has launched its program to audit 6000 companies in the next few years. The audits will focus on employment taxes in general, and particularly on fringe benefits. A discussion of the kinds of documents and records the auditors will want to see. Page 3

Positive Tax Changes in Massachusetts
Under a law signed in the first week of August, the carry-forward period for net operating losses has been increased to 20 years (from 5 years) and the state tax on qualified small business stock has been reduced to 3 percent. Page 12

New York and New Jersey Tighten Rules for Unclaimed Property
Separate legislation recently signed into law in New Jersey and New York reduce the dormancy period of unclaimed property, and, in New Jersey, expand the types of property that are subject to automatic transfer to the state. Page 13

Practical US/Domestic Tax Strategies Archives
10 Jan 2008

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