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Corporate & Business Law - Product Update
5/22/2008 2:49:26 PM EST
Business Organizations with Tax Planning
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Chapter 64 was revised to summarize the requirements of accounting for tax position. In addition, it includes discussion of the safe harbor for the bank accrual of interest and discussion of treatment of advance payments under Revenue Procedure 2004-34, which supersedes Revenue Procedure 71-21. Chapter 64A was updated to include expanded coverage of treatment of installment sales when a purchaser who is related to the seller resells the property within two years after the first sale. Chapter 65 updates the list of expenditures subject to special amortization provision. In addition, the revision updates treatment of start-up and organizational expenditures and adds a new section on deduction of geological and geophysical expenditures. Chapter 66 was updated to discuss the Code provision designed to address the use of partnerships to avoid the disqualified interest rules. In addition, the revision adds new subsections on the disallowance of interest deductions for disqualified debt instruments (instruments payable in equity of the issuer or a related party) and denial of the deduction for any interest paid to the federal government on any underpayment of tax attributable to the portion of any reportable transaction understatement that has not been adequately disclosed.

Business Organizations with Tax Planning

 

 

 

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