SUMMARY : Johnson Controls and other corporate taxpayers challenged Kentucky legislation that barred refund claims based on the state's change from separate return to combined filing. The Kentucky Supreme Court denied the taxpayers cont ...

Summary : While TARP's requirements are technically limited to the most highly paid employees in the companies receiving TARP funds, they promise to have far-reaching implications for executive compensation best practices. This Emerging ...

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The United States remains a magnet for foreign investment, troubled times notwithstanding. Whether the wealth coming into the U.S. is accompanied by its owners, whether or not the owners intend to remain here indefinitely, or whether the investments ar ...

A challenge encountered by tax practitioners when attempting to draft target partnership allocations is how to deal with nonrecourse liabilities. The target allocation provision may satisfy the nonrecourse deduction safe harbor if allocations under the ...

Applying target allocations is one way to allocate income, gain, loss, deduction from a partnership. Target allocations say how cash is distributed from operations and in liquidation. This allocates income and loss to partners capital accounts so these ...

The poor economy has created a budgetary crisis for many state governments. One solution is to expand a state's taxes to include companies earning income or with benefits that are seen occurring in the state. There are controversies on "attributio ...

In the past several years, Judge Sheryl Ramstad has decided no less than seven cases in favor of go ...

Under the Michigan Business Tax Act, every taxpayer with business activity in the state is subject to the business income tax. The business income tax base, which is a taxpayer's "business income" as defined in Continue reading >>

SUMMARY: In sustaining the constitutionality of Ohios Commercial Activity Tax (CAT) as applied to the gross receipts from the sale of food for human consumption, the Ohio Supreme Court has reaffirmed the prin ...

Summary : In 2008, New York enacted the Amazon Tax Law, requiring certain e-tailers to collect and remit tax on sales to NY residents. The law has created controversy as to whether the relationship between the e-tailers and the in-state ...

It is important to properly draft target allocation provisions, by examining a variety of such provisions. Certain partnership allocations concern income, gain, loss, and deductions, called target allocations. Target allocations specify how cash is dis ...

The global economic crisis has two diametrically opposed aspects, as things stand today. The first of these has created the current focus on economic stimulus; of getting consumers to consume; of encouraging lenders to lend; and of reenergizing the ban ...

Summary : Prior to the unification of PRC Enterprise Income Tax (EIT) systems for domestic enterprises and Foreign Invested Enterprises (FIEs), different rules were applied to combined EIT filing by domestic enterprises and FIEs having ...

SUMMARY : The deductibility of premiums is a potential tax benefit in a corporation forming a captive insurer. The courts have limited the deductibility of premiums to those situations in which the insurance issued by the captive is act ...