Employee home transactions by relocation companies: a critical analysis David J. Roberts In a recent National Office Technical Advice Memorandum (TAM), [1](*) the Internal Revenue Service ruled that a taxpayer that contracted with relocation companies (relos) for the purchase and sale of homes owned by the taxpayer’s employees will be treated as having purchased and […]
Category: Tax Executive, The
The new penalty regime finally arrives: proceed with caution! Herbert N. Beller We all knew it had to happen sooner or later. After several false starts, Congress recently passed a robust package of anti-tax shelter measures as part of the American Jobs Creation Act of 2004 (the “Jobs Act”). (1) The centerpiece of the tax […]
State tax treatment of net operating loss carryovers in corporate acquisitions Peter L. Faber Introduction Many state tax statutes, unlike their federal counterpart, do not provide for the transfer of net operating loss carryovers (NOLs) from one corporation to another in an acquisition. These statutes typically provide that NOLs can be carried forward by a […]
New section 409A: a revolution in the world of deferred compensation Norman J. Misher I. Introduction On October 22, 2004, President Bush signed into law the American Jobs Creation Act of 2004. The Act added section 409A to the Internal Revenue Code, which governs the taxation of nonqualified deferred compensation plans. The new provision will […]
Comments on proposed information reporting penalty regulations On behalf of Tax Executive Institute, I am pleased to submit these comments on the Internal Revenue Service’s temporary and proposed regulations under sections 6721 through 6724 of the Internal Revenue Code, relating to the imposition of penalties for failure to comply with information reporting requirements. The temporary […]
TEI-IRS interview on Voluntary Compliance Resolution Program – IRS official William Hulteng – Interview David L. Klausman On May 10, 1993, David L. Klausman of Westinghouse Electric Corporation, Chair of TEI’s Subcommittee on Employee Benefits, and Jeffery P. Rasmussen of the Institute’s Legal Staff interviewed William Hulteng–Chief, Rulings Branch (Employee Plans/Exempt Organizations) for the Internal […]
Managing an IRS audit: practical insights and techniques – Interview Donald L. Herskovitz This is an edited transcript of an interview on Managing an IRS Audit. The interview was completed as part of an audiotape series produced by the Deloitte & Touche LLP Washington National Tax Group on various tax topics. Donald Herskovitz (DH) is […]
CEO’s perception of the role of tax management Barry P. Arlinghaus CEO’s Perception of the Role of Tax Management INTRODUCTION Taxes have always been a significant cost of doing business. With federal, state, local, and provincial governments looking for increased and new sources of revenue, the effect of taxes upon corporate profitability will become even […]
Proposed section 482 regulations – includes related article On July 28, 1992, Tax Executives Institute filed the following comments with the Internal Revenue Service on the proposed section 482 regulations relating to transfer pricing and cost sharing. The proposed regulations are intended to implement the commensurate-with-income standard of section 482 which was enacted in the […]
The new Section 355 checklist questionnaire Donald L. Herskovitz Section 355 of the Internal Revenue Code of 1986 provides for tax-free treatment of the separation of one or more active businesses through the distribution by a corporation (Distributing) of the stock or securities of a controlled corporation (Controlled), either existing or newly formed by the […]