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Final Regulations Amplify the Expanded Affiliated Group Production Incentive |
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The Expanded Affiliated Group provisions cause companies that are members of the same affiliated group to be treated as one entity. The IRS, in promulgating the Code Sec. 199 domestic production final regulations, added an extensive number of examples to illustrate the Reg. §1.199-7 EAG provisions.
In their article in Corporate Business Taxation Monthly, Robert Feinschreiber and Margaret Kent explain the legislative background of the EAG provisions and how they work, revealing why the Code Sec. 199 EAG provisions may have a broader impact than the earlier, proposed domestic production EAG provisions.
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Court Options Available After Appeals |
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Most taxpayers successfully resolve their tax issues with the IRS at Appeals, but what can you do if you do not reach a conclusion that you consider satisfactory? Choosing the Tax Court option offers you a judge knowledgeable in tax matters, plus you do not have to pay the tax first. District Court could be better if the contested issue centers on the facts rather than the law.
Ray Moore, in his article in Executive's Tax & Management Report, shows you when to choose and when not to choose either Tax Court or District Court.
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Planning for Outbound Reorganizations-An Introduction |
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Treatment of certain cross-border, outbound acquisitions as tax-free reorganizations has important consequences. Tax planning for an outbound reorganization requires an understanding of the general rules applicable to reorganizations, as well as the rules of Code Sec. 367 (a) and (d).
David Buss, David Hyrck, and Robert Rothman, in their column in Taxes-The Tax Magazine, explain the careful legal analysis and planning essential to ensure the intended tax treatment to all parties.
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Sales Factor Treatment of Sales and Redemptions of Securities in the Aftermath of General Motors and Microsoft |
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To Convert or Not to Convert, That is the Question |
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| Stay informed on key new business taxation developments |
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Executive's Tax & Management Report |
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| Wealth-building strategies plus late-breaking news |
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Taxes-The Tax Magazine |
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Insightful articles and columns on current tax issues, trends and hot topics |
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Journal of Taxation of Financial Products |
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Journal of Retirement Planning |
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| Practical, timely information on one of the most important aspects of financial planning |
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LIFO: Concepts, Applications and Opportunities (PART 1)
Audio Seminar |
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| Learn the basics of using the last-in, first-out (LIFO) inventory valuation method |
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| Thursday, July 26th at 1pm Eastern, noon Central. Register now for this insightful program! |
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