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The article explores the other-state tax credit for personal income tax, examining the classification of specific business taxes for credit purposes, the inclusion of local city taxes, and the determination of creditability for taxes paid to non-states. It mentions developments in California, illustrating how states analyze these issues and the potential impact on taxpayers deriving income from multiple jurisdictions.

The article reports that New Mexico Governor Michelle Lujan Grisham has signed House Bill (H.B.) 6, enacting major changes in the state's corporate income tax and gross receipts tax (GRT) regimes. It mentions changes to the GRT came primarily in response to the U.S. Supreme Court decision in South Dakota v. Wayfair, Inc. It also mentions way for states to enact economic nexus laws requiring out-of-state businesses to collect sales and use tax from in-state customers.

The article discusses the Supreme Court's decision in "South Dakota v. Wayfair Inc." which invalidated the Supreme Court's long-standing precedent that a business must have a physical presence in a state for the state to require the business to register for, collect, and remit sales and use tax to the state. It reports that due to the decision states that impose a sales tax have updated their statutes to include economic nexus thresholds for out-of-state seller.

The article explores the federal law and process for the new federal partnership audit regime in the U.S., as of December 2018. Topics discussed include provisions under model uniform statute for reporting adjustments to federal partnership audit adjustments; changes in the federal audits of partnerships to ensure tax agencies can administer their state taxes in conjunction with federal laws; and impact of the 2018 Hawaii legislation on partnerships subject to a federal audit.

The article examines the laws related to taxation of worthless and abandoned partnership interests in the U.S. Topics discussed include worthlessness of a partnership interest; abandonment of a partnership interest; character of a loss on abandonment of a partnership interest; and allocated partnership liabilities at the time of abandonment.

The article examines the state tax issues that arise under Accounting Standards Codification (ASC) 740 for privately held business entities organized as flowthrough entities. It reports that with ASC 740's broad definition of income tax, most state assessments, including some franchise taxes, qualify as income tax payments under the ASC 740 umbrella. The California Franchise Tax Board's affirmation that the Texas margin tax is an income tax, Ohio's commercial activity tax (CAT), and the Michigan business tax (MBT) are among topics discussed.

The article offers tips to small- and medium-enterprises (SMEs) on minimizing their exposure to inter-company pricing adjustments under audit through advance pricing agreements (APAs) approved by the U.S. Internal Revenue Service (IRS). SMEs with controlled foreign affiliates are allowed by the IRS to use an APA in order to ascertain the appropriate transfer pricing method (TPM) for their business transactions. The advantages of the APA are mentioned.

The article discusses the growth in the adoption of the so-called mandatory unitary combined reporting methods in the U.S. It explains varied definitions of a unitary business concept in West Virginia, Massachusetts and Wisconsin. It explores the computation of taxable income in West Virginia, in which each member is liable for tax according to taxable income or loss. It elaborates the Joyce-Finnigan method employed in Virginia in which combined group members use a formula that consists of property, payroll and double-weighted sales.

• A partnership can distribute real property to its partners so that the partners can exchange the property in a Sec. 1031 like-kind exchange; if the exchange is properly structured, some of the partners can trade their interests in the property distributed in Sec. 1031 exchanges and some of the partners can sell their interests in the property in taxable transactions. • When challenging the validity of a Sec. 1031 exchange of property distributed by a partnership, the IRS will likely use one or more of three theories: (1) the partners did not hold the property for a qualified use, (2) the step-transaction doctrine, and (3) the partners' cotenancy in the property is a partnership. • As an alternative to distributing the property before the exchange, a partnership could exchange the property for cash and installment notes, buy replacement property with the cash, and distribute the installment notes to partners who wish to withdraw from the partnership. [ABSTRACT FROM AUTHOR]

* A conversion of an entity treated as a partnership to an entity treated as a sole proprietorship could come about when one partner purchases all the remaining outstanding ownership interests in a partnership or when all the partners of a partnership sell their interests to a single third party. * A conversion of an entity treated as a sole proprietorship to a partnership could come about when a third party purchases a membership interest in a solely owned entity from the existing owner or when a third party contributes cash or property to a solely owned entity in exchange for an interest in the entity. * Three transaction forms, which each result in different tax consequences, are available for incorporating a partnership. * A partner typically exits a closely held partnership either by selling his or her partnership interest to the remaining partner or through a liquidation of the partner's interest by the partnership. [ABSTRACT FROM PUBLISHER]

The article focuses on Tax court case Harkins v. The RV Factory, LLC on business deductions for the use an RV taken on the returns of a corporate entity owned by the taxpayers were found to be evidence that the taxpayers. It mentions RV Factory moved for summary judgment on issue of material fact and the moving party is entitled to judgment as a matter of law. It also mentions actions taken to maximize tax deductions can have deleterious nontax effects.

Explores the issues surrounding residency of an individual involved in a business and its tax implications in the U.S. Common factors used in determining an individual's domicile; Description of an income tax domicile; Discussion of incomes sourced to the state; Considerations for taxpayers who work and/or reside in more than one state.

Identifies some common issues that a tax adviser faces when a divorcing client or spouse owns a closely held business. Valuation of the business; Pre- and post-nuptial agreements; Shareholder buy-sell agreements; Trusts and asset protection; Tax liabilities.

Part I. Explores the benefits of using limited liability companies (LLC) to maintain personal liability protection for business owners, while maximizing the income and self-employment (SE) tax benefits of business losses in the U.S. Legal advantage of an LLC over general partnership and sole proprietorship forms; Exceptions to the treatment of a liability partnership for SE tax purposes; Provisions of a proposed regulation for the use of LLC for SE tax purposes.

The article examine the U.S. Internal Revenue Service (IRS) Revenue Procedure 2015-20 that require small business taxpayers to adopt the final tangible property regulations using simplified procedures. Topics discussed include tangible property regulations' small business exceptions; tangible property regulations; and process of adopting the tangible property regulations for small business taxpayers in the country.

Discusses the US Internal Revenue Service's (IRS) Section 7701 entity classification final regulations (check-the-box regulations) governing the tax classification of domestic and foreign businesses. Recognition of separate entity; Business entities; Corporate classification; Eligible entity; Foreign eligible entity; State tax considerations; Elective classification.

Discusses the US Internal Revenue Service's (IRS) proposed regulations that provide rules for determining a consolidated group's alternative minimum tax (AMT) liability and for allocating various consolidated AMT attributes to members of the group. Separate-company basis; Consolidated basis.

Discusses the minimum criteria in establishing the conditions under which the courts may allow a business bad debt deduction. Debt versus capital contribution; Guarantors' losses; Business versus nonbusiness bad debt; Trade or business of being an employee; Trade or business of acquiring corporations; Timing of the deduction.

The article reports that certain entities can elect passthrough tax treatment for U.S. federal tax purposes by simply checking the box indicating whether the taxpayer is a disregarded entity or a partnership. Recommendations are made for those faced with uncertainty in making an election for passthrough treatment, including what to do if a taxpayer has determined it has checked the wrong box. The Revised Procedure 2010-32 is cited as a well-intentioned but limited attempt to provide an efficient mechanism to ensure an entity's correct classification.

The article focuses on the rules of the U.S. Internal Revenue Code's Section 41, Chief Council Advice (CCA) 200234063, Technical Advice Memorandum (TAM) 200330001 and 201034017 on research tax credits for consolidated groups. Section 41 treats all members of a group as a single taxpayer in which research credit is calculated for the entire group and then apportioned to the group members. Under the CCA 200234063, all the qualified research expenses of the target corporation are included in the computation of credit.

The article discusses the issues involved when qualifying receipts as sponsorship payments or advertising income for non-profit or exempt organizations. This report cites the different methods that nonprofit organizations use to obtain funding as an exempt entity, including annual banquets or sale of raffle tickets. It also notes that by implementing unrelated business income tax non-profit firms are prevented from engaging in unfair competition with profit-making companies by avoiding tax consequences.

The article focuses on the application of the American Institute of Certified Public Accountants (AICPA) Business Valuation Standards in tax practice. They apply to subject interests defined as a business, business ownership interest, security, or intangible asset and recognizes valuation engagement and calculation engagement for estimating value. They can be used for estate planning if the client asks to calculate the value of the subject interest. Some of its exceptions are attest engagement and internal use of assignment to employee.

The article focuses on the Michigan Business Tax (MBT). An overview of the tax is provided. According to the article, the issues for a taxpayer to consider when determining its MBT liability are the definition and scope of gross receipts, the gross receipts tax (GRT) deduction for purchases from other firms and changes in the sales factor calculation.

Discusses the taxation policies on a business directly affected by Hurricane Katrina in the U.S. in 2005. Benefits that will be received by employees affected by the hurricane; Requirements for a business for claiming benefits; Deadline for submitting applications for the benefits; Limitations on the benefits.

Discusses tax practice and procedures concerning large and mid-size businesses and offers-in-compromise in the U.S. Problems posed the industry-alignment approach of the U.S. Internal Revenue Service (IRS); Final regulations issued by the IRS about offers-in-compromise.

Reports on the ruling issued by the U.S. Internal Revenue Service for grouping a taxpayer's trade or business activities and rental activities for purposes of applying passive activity loss (PAL) limitation rules. Factors which receive the greatest weight in determining whether activities are an appropriate economic unit; details of the case of the company Glick which owned interests in several partnerships and a management company.

Provides information on tax outsourcing of companies. Origin of outsourcing; Branches of the tax function; Details on opportunities to begin a transition to tax outsourcing; Information on outsourcing agreements.

Focuses on the initiatives on tax issue resolution launched by the Appeals Division of the Large and Mid-Size Business Division of the United States Internal Revenue Service as of January 1, 2002. Goals of the initiatives; Introduction of the mutually accelerated appeals process; Information on the fast track dispute resolution.

Presents a case illustrating tax regulations affecting disregard of corporate entity in the United States. Revocation of the company's certification by the US Federal Aviation Administration; Personal liability of the company's founder in paying withholding taxes; Ruling by the US Internal Revenue Service (IRS) on the taxes' payment.

Focuses on developments in the limited liability company form of business organization in the United States as of March 1994. LLC characteristics; LLCs with one member or related members; Advantages and disadvantages of the widespread adoption of LLC; Tax features of the LLC form of business organization.

Presents scenarios on how the existence of a partnership can make a substantial difference in how a client is taxed. Taxpayers entering into a `Participation agreement'; `Participating interest'; Bankruptcy and no filing of partnership return; Taxation; Taxpayer entering into an arrangement with a real estate broker; Agreement entitled `Letter of Agreement'; Issue on whether or not to make a Section 453 election.

The article discusses how acquired target corporations (ATC) can avoid denial of extension requests on business tax filing forms. Topics include the electronic filing of consolidated returns, the preparation of short-year tax returns, and U.S. Internal Revenue Service's (IRS) rejection of Form 6513 Extension of Time to File requests.

The article reports on the move by the U.S. Internal Revenue Service (IRS) to release proposed regulations concerning the tax treatment of series limited liability companies (LLCs) and foreign cell companies. Under the proposal, individual series LLCs or cells are to be treated as separate entities. The IRS has decided that the factors favoring the disregard of the series as separate entities are being outweighed by the factors that support the separate entity status. It stresses that the proposal only affects the series within series LLC.

The article describes a case concerning the conversion of a C corporation into a limited liability company (LLC). It states that the liquidation of the corporation, which results in a double tax, is essential in the process of conversion. Shareholders, however, are allowed to enjoy the benefits of limited liability together with the advantages of passthrough taxation, although the tax cost a conversion could entail is usually heavy.

The article focuses on the plan of the U.S. Internal Revenue Service (IRS) to require corporate taxpayers with total assets in excess of 10 million dollars to report uncertain tax positions. It notes that the IRS is working on a schedule that will be used by the taxpayers as they disclose uncertain tax positions on their annual returns. Doug Schulman, IRS commissioner, has stated in a meeting that such requirement will lead to more efficient corporate audits. Details that need to be included in the description of each uncertain tax position are given.

The article provides insights on whether the taxpayer can deduct the costs of the feasibility study of his or her business. According to Section 195(a) of the U.S. Internal Revenue Service, no deduction shall be allowed for start-up expenditures. It stresses that the taxpayer would have to prove that it is already engaged in a particular trade or business under Section 162 to be able to take a deduction.

Discusses the policies imposed by the U.S. Internal Revenue Service on accounting for casualty losses during a national disaster. Individuals and businesses that are eligible for a tax relief; Requirements for applying the relief; Procedures for filing applications for the relief.

Reveals that the use of traditional state tax planning strategies generally provide no state tax benefit in unitary states in the U.S. Way for a taxpayer to realize the benefits from intercorporate transactions in unitary states; States in which a combined income tax return excludes an 80/20 company in part or in whole; Methods to establish a corporation as an 80/20 company; Requirement for an 80/20 company to minimize a state audit challenge.

Focuses on a regulation by the United States Internal Revenue Service in which a taxpayer cannot take deductions for business expenses connected to rental income for a home office used exclusively for business. Overview of Sec. 280A(c)(6) regarding the treatment of rental to employer; Reason for issuing the regulation.

Focuses on tax considerations for accountant's clients who are planning to start a business venture. Guidelines which can be used to focus on issues confronting a client who is considering starting a business.

Focuses on regulations from the US Internal Revenue Service (IRS) on the tax deductibility of business expansions following the case of INDOPCO Inc. Rules stipulating the deductibility of expansions; Determinants of expansion costs' necessity on business operations to qualify as deductibles. INSET: Trends in inventory management..

Discusses the qualification of computer software projects internally developed by businesses for the research and experimentation (R&E) credit in the United States. Percentage of credit of excess qualified research expenses provided under Section 41; Criteria for qualified research; Tax Reform of 1986; Situations in which the costs software will be eligible for the R&E credit.

Discusses Section 162 of the Revenue Act of 1978 about the tax treatment of incidental repairs related to trade or business. Expenses treated as capitalizable costs; Ruling of the Supreme Court in the case of INDOPCO.

Discusses the policy on the taxation of membership organizations exempt under Section 501(c)(7) of the Internal Revenue Code. Investment income as unrelated business income subject to tax without offsetting deductions; Section 457 deferred compensation plans for executives and employees; Internal Revenue Service ruling for the transfer of funds from one eligible compensation plan to another.

The article reports on a guidance posted by the U.S. Internal Revenue Service (IRS) to its website that urges taxpayers to submit their delinquent Forms 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, before January 1, 2009. Such date is set for the implementation of automatic assertion of penalties under Section 6038 on late-filed Forms 1120, Corporation Income Tax Return, which includes Forms 5471. It explains the benefit of electronic filing of Forms 1120 to the IRS.

Discusses the ruling of the U.S. Seventh Circuit Court on a financial hardship defense to the failure of a manufacturing company to pay employment tax returns for 1998 and 1999 and to timely deposit its corresponding tax liability. Background on the case; Provisions of a tax regulation on the failure of the employer; Circumstances that are not present in the defense presented by the company.

Reports that there are a number of companies who are not ready to start making electronic Federal tax payments via the Electronic Federal Tax Payments System (EFTPS) by the July 1, 1997 deadline. Estimated number of companies to use EFTPS; How a taxpayer will be able to retrieve an incorrect EFTPS; Reference to the penalty for failure to file electronically.