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Offers several taxation issues in the United States. Reason why Senate Budget Committee Chair Pete V. Domenici rescheduled the markup of his budget blueprint; Problem on the effectiveness of Line Item Veto Act; Ways considered by House Ways and Means Committee member Rob Portman to restructure the tax code; Information on coordinated system created by Internal Revenue Service (IRS) for correcting pension plan violations.

Highlights the Streamlined Sales Tax Project in the United States. Distinction between exemptions and exclusions of taxes; Approval of bills allowing multistate sales tax discussion; Cooperation of the National Conference of State Legislatures Definition with the project.

Reveals the mechanics of the Guam resident trust tax shelter described in a memorandum by lawyer Daniel Berman, partner at Sutherland Asbill & Brennan. Benefits for the trust estate business and insurance companies; Complications of the law that is supposed to produce the desired tax rebate scheme; Guam's qualification as a tax haven.

Focuses on the proposed rule that prevents tax evasion on real estate mortgage investment conduits income in the United States. Overview of the phantom income and loss phenomenon; Impact of the tax shelter market on the price of inducement fees; Proposed regulations by the New York State Bar Association Tax Section.

Focuses on the various aspects of pension plans. Definition of a comparability plan; Federal regulation in the United States that permit cross-testing; Proposal to implement comparability plan regulations; Historical justification for cross-testing.

Focuses on the debate over two pension bills pending in the United States Congress, as of October 9, 2000. Proposal to integrate private taxable savings into a tax-advantaged qualified retirement plan savings; Census Bureau figure for the median household income; Purposes of nondiscrimination rules; Goal of the tax qualification for private deferred compensation plans.

Focuses on Senator Charles Grassley's reaction to a United States General Accounting Office's report about top-heavy rules for qualified retirement plans. Effective backstop to the general qualified plan nondiscrimination rules; Benefits for lower-paid workers; Similarity to the alternative minimum tax.

Focuses on the debate over cash balance plans in the United States (U.S.). Senator Charles Grassley's advocacy of cash balance plans; One of several unfair practices in the pension area; U.S. General Accounting Office's issuance of two reports on cash balance plans; Benefits of the plans for younger, more mobile workers.

Analyzes developments concerning the conversion of defined benefit plans in the United States to cash balance plans. Hostile rulings handed by federal judges concerning cash balance plans; Biased portrayal of employers' benefits from the conversion; Avoidance of the reversion tax.

Reports on the reform of the pension system in the United States. Desire of Republican Congress to raise the contribution limits for defined contribution plans; Participation in employer's employee-funded defined contribution plans.

Focuses on United States Treasury Department's belated discovery of taxpayers' abuse of check-the-box rules in foreign settings. U.S. Internal Revenue Service's commitment to curbing corporate tax avoidance; Disagreement between those want to address abusive transactions through the specific rule being abused and those who want to write antiabuse rules; Definition of 'extraordinary transaction.'

Reports on the stand of the Multistate Tax Commission on pending Internet tax legislation during its 33rd Annual Meeting in Alaska. Scope and parts of the resolution to extend Internet Tax Freedom Act moratorium on Internet access taxes in the United States; Defeat of the resolution calling for repeal of the grant of federal jurisdiction over the Railroad Revitalization and Regulatory Reform Act of 1976.

Analyzes the issues of corporate tax shelters in the United States. Comparison of comedienne Fran Drescher's whining with that of New York tax lawyers'; Protection of lifestyles of promoters and facilitators; New York State Bar Association's views on the merits of writing and economic substance doctrine into the law; Issues relating to cottage savings; Concept of risk of loss.

Comments on why the Europeans do not like American products. Foreign sales corporation (FSC) case filed by the Europeans on the World Trade Organization (WTO); Proposal of the Americans to the Europeans; House Ways and Means on the proposal; Qualifying foreign trade property/income. INSET: FINANCE CONFIRMS TALISMAN..., by Marybeth Feliciano..

Examines the foreign factoring tax shelter that has a passive foreign investment company (PFIC) question in the United States Internal Revenue Service and U.S. Department of the Treasury's 2000 priority guidance. Reasons of designers of the foreign factoring shelter for differentiating a foreign factoring company from a PFIC; Anti-shelter potential of the PFIC guidance. INSET: TIMELINE OF ACTIVE BUSINESS EXCEPTION..

Examines the final section 894 regulations covering tax treaty benefits in the United States. Elimination of the beneficial owner requirement; Fiscal transparency; Double nontaxation of domestic reverse hybrids.

Reports on the American Bar Association House of Delegates' vote to oppose any changes to the Model Rules of Professional Conduct that would permit lawyers to share fees with non-lawyers. View of most lawyers that multidisciplinary practice will continue to flourish regardless of the organization's position; Independence from the client; Lawyer's role as advocate.

Examines the possible tax consequences of futures market deregulation in the United States. Proposed exemption of equity swaps from Commodity Futures Trading Commission regulation under the 1936 Commodity Exchange Act; Role played by taxes in augmenting the safety and enforceability of equity swaps; Regulation of derivatives clearing organizations; Implications for single-stock futures trading.

Reports the status of the bankruptcy bills in the United States House and Senate as of June 12, 2000. Impact of the bills to credit card lenders; Purpose of bankruptcy administration; Details on some provisions of the Bankruptcy Code.

Discusses the mischief potential of reverse hybrids resulting from the extension of the check-the-box privilege in the United States to foreign taxpayers that are not corporations per se. How to get tax benefits associated with foreign income; Concerns over who is entitled to the treaty benefits.

Discusses a transaction in which a B reorganization used to avoid the section 956 investment in United States property trap has been packaged as a corporate tax shelter. Information on the transaction; Case that signaled the beginning of the end of the argument of the purposes of subpart F could stand in for the statute.

Reports on a bill that would extend the Internet tax moratorium approved by the United States House of Representatives in May 10, 2000. Details on the bill; Cost of eliminating a grandfather clause to states; Argument of Representative John R. Thune (R-S.D.); Information on an amendment establishing provisions for a multistate sales compact. INSET: GOP OUTLINES ANTITAXATION E-COMMERCE AGENDA.

Offers a look at the tax returns of United States (US) first lady Hillary Rodham Clinton and Tipper Gore, wife of US Vice President Al Gore. Reported adjusted gross income of the Clintons; Sources of income for the Gores; Tax preparer used by the Clintons and Gores.

Discusses issues concerning corporate tax shelters in the United States. Why the publication `Tax Notes' has shied away from using adult humors; Details on the Bond and Option Sales Strategy transaction; Several legal cases concerning partnership between a parent and a subsidiary company.

Deals with the report issued by the United States (US) Internal Revenue Service on its advance pricing agreement (APA) program that prevents the disclosure of APA by corporate taxpayers. Criticisms on the report; Motive of the US government with its APA program; Types of taxpayers coming in for APA; Model APA included in the report.

Addresses the main question over the final scheduled meetings of the United States Advisory Commission on Electronic Commerce. Collapse of the negotiations between public and private-sector interests; Details on the controversial business caucus proposal; Merits of the business proposal. INSETS: CARL S. SHOUP, FORMER TREASURY ECONOMIST, DIES;INTERNET COMMISSION FAR FROM SUPERMAJORITY.

Focuses on a document labeled as memorandum, one of the legal opinions used by the investment banker in the case, ACM Partnership versus Commissioner. How the memorandum was furnished by one former government official to another; Summary of the installment sale shelter.

Provides information on the implementation of the concept of stripping in tax shelter in the United States. Definition of stripping; Requirement of the government on income stripping; How corporate taxpayers can create their own tax shelters.

Focuses on a tax law in the United States (US) which insurance companies are complaining about because their competitors are avoiding their US tax liabilities by escaping to Bermuda. Kinds of insurers that are using Bermuda to avoid US tax; Ways for the US government to claim income from Bermuda-based insurance companies; Operation of reinsurance companies in Bermuda; Proposal to address the Bermuda problem.

Discusses issues concerning the United States (US) Internal Revenue Service's (IRS) regulations on debt cancellation (COD) income. Arguments of taxpayers on COD income; Examples of S corporation cases regarding the issue; Conclusions of three circuit courts on the S corporation shareholder basis issue; Judge Posner's interpretations of the US IRS code.

Discusses issues concerning the disclosure regulations on corporate tax shelters in the United States. Types of corporate tax shelter transactions; Exemptions from disclosure; Definition of what it is for a corporation to have a purpose of federal tax avoidance.

Focuses on the legal arrangement of divorced couples in the United States. Background information on divorce negotiations; Issue on the transfer of property of the spouse; Rules on divorce tax; Cases of divorced women who demand from their husbands; Tax treatment of the spouse who is receiving financial settlement in a divorce; Issues related to taxes of conjugal properties of divorced couples.

Discusses what transpired in the New York University/Tax Analysts Seminar for Government held on February 11, 2000. Necessity of transfer taxes; Reaction of the participants to news of growth in transfer tax receipts; Issue over family limited partnerships.

Focuses on the corporate tax proposals in the 2001 budget proposal of President Bill Clinton's administration in the United States. Corporate tax shelters; Offshore tax and banking havens; Tax-free formation of swap funds.

Deals with the issuance of the United States Financial Accounting Standards Board (FASB) in 1998 of the FAS 133 which requires reporting companies to record derivatives at fair market value as assets and liabilities on the balance sheet. Definition of derivative; Exclusions from capital asset treatment; Difference between the accounting and tax rules for hedges.

Looks at the tax questions raised by PHONES, the equity-linked hybrid securities that are intended to be treated as contingent payment debt for tax purposes, and the government's plans to deal with them in the United States. Equity to which the PHONES are linked; Description of the PHONES; Issues considered whether PHONES be subject to the contingent payment debt rules.

Examines the significance of the decision on the tax case Twenty Mile Joint Venture, et al. versus Commissioner on the issue of debt discharge in the United States. Facts of the case; Corresponding jurisprudence; Paradox of the decision.

Reports the proposal of United States presidential nominee Bill Bradley on business taxation. Characteristics of his proposal; Details on his suggestions on corporate tax shelter. INSET: A Quick Review of Shelter Revenue Estimates.

Questions the repeal of the installment method for accrual method taxpayers. Taxpayers allowed to use the installment method; Details on the Ticket to Work and Work Incentives Improvement Act; Why the liquidating sale of the assets of ineligible corporations are considered as special cases.

Provides information on the discussions of the Advisory Commission on Electronic Commerce (ACEC) on tax systems for electronic commerce. Imbalance in the membership of the ACEC; Details on the NTA Project's final report in September 1999; Impact of the introduction of the Mobile Telecommunications Sourcing Act.

Highlights the Internal Revenue Code of 1986 focusing on inventory rules in the United States. Provisions; Issue on Medicare prescription drug benefits; Cases in the Tax Court.

Examines the United States Treasury Department's questionable uses of the so-called check-the-box rules for foreign subsidiaries of United States corporations. Threat to crack down on foreign hybrid branch abuses; Tax practitioners' concerns regarding complications of a tax-free subsidiary liquidation; Use of tax nothing elections to foreign tax credit restrictions.

Focuses on the implications of PricewaterhouseCooper's new product the bond & option sales strategy (BOSS). Formation of limited liability company in the Cayman Islands as required by the BOSS; Tax planning services.

Discusses the case of Bruno's Inc., a supermarket chain that is using bankruptcy in an innovative way to make beneficial transaction. Debate over transaction between Richard Lipton of Sonnenschein Nath & Rosenthal and David Hariton of Sullivan & Cromwell; Features of the section 269; Other provisions pertaining to transaction and bankruptcy.

Deals with the issue of penalties asserted against taxpayers in the United States who are willing to argue about the nature and extent of their liabilities. Adversarial; Issue on the tax shelter portion of Circular 230; Opinions; Imposition of negligence penalty; Argument raised by the Treasury Department for retaining the differentials between interest paid on corporate overpayments and interest imposed on underpayments.

Examines the United States government's victory in the corporate tax shelter case involving interest deductions claimed by Winn-Dixie Stores Inc. Background of the case; Details on the litigation; Information on other government victories in corporate tax shelter cases.

Focuses on the United States Internal Revenue Service's 1999 proposed rules regarding the distribution of tax among shareholders during the mergers of corporations. Definition of acquisition according to the proposed batch of section 355; Proposed reorganization control requirement of section 368; Implication of the planned changes on the rule.

Assesses what the United States (US) tax law should do about tracking shares. Background on tracking shares; Opposition by the New York Bar Association on the treatment of tracking shares; Treatment of the issuance of tracking shares as a property distribution to shareholders.

Commends the move of United States Tax Court Chief Judge Mary Ann Cohen to combat corporate tax shelter problem. High standard of Judge Cohen on what constitute corporate tax shelter abuse; Analysis on some of the cases dealing with corporate tax shelter abuse she decided; Facts on the cases; Foreign tax credit policy.

Reports on the proposed anti-Morris Trust or section 355 laws in the United States. Purpose of the change in Morris Trust; Why section 355(e) law does not affect Morris Trust facts; Elements of the alternative rebuttal test of proposed regulation 1.355-7(a)(2)(iii); Comments from Michael Schler of Cravath, Swaine & Moore.