Example 1: Buyer pays $100 cash for nuclear plant worth $100 (seller’s basis is $50) subject to an environmental clean-up liability of $500 (present value based on section 483 principles), plus a fund that seller has built up containing $500 … [Continue reading] about Nuclear Decommissioning Funds
Report of the President’s Economic Recovery Advisory Board
Report on Tax Reform Options: Simplification, Compliance, and Corporate Taxation The PERAB or “Volker Commission” has issued its Report on Tax Reform Options: Simplification, Compliance, and Corporate Taxation. It is a noble effort. It … [Continue reading] about Report of the President’s Economic Recovery Advisory Board
North Carolina Inches Toward Voluntary Combined Filing
North Carolina long has been a “single entity” state for purposes of state corporate income tax filing. However, since the late 1990s the NCDOR has issued perhaps hundreds of assessments based on “forced combinations” under … [Continue reading] about North Carolina Inches Toward Voluntary Combined Filing
Foreign Tax Credits Limited by H.R. 1586
Effective August 12, 2010 H.R. 1586 adopted several rules tightening the rules allowing the use of foreign tax credits. The limitations aim to more closely align the credit use with the reporting of the associated tax, to reduce the amount of foreign … [Continue reading] about Foreign Tax Credits Limited by H.R. 1586
Leveraged Partnership Fails and “Should” Opinion Did Not Prevent Penalty
In Canal Corp. v. Commissioner, 135 T.C. No. 9 (Aug. 5, 2010) the Tax Court ruled that a corporation in effect “sold” the business of its subsidiary when the subsidiary contributed the business assets to a partnership with another company … [Continue reading] about Leveraged Partnership Fails and “Should” Opinion Did Not Prevent Penalty