On this edition, Robert Jennings and Elizabeth Taishoff Sweigart discuss the Economic Substance Doctrine and corporate tax positions related to affiliate transactions. They examine these principles in the context of Schering-Plough v. U.S., and analyze essential elements of economic substance and non-tax business purpose, comparing IRS policy with the position of international tax authorities. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.

On this edition, Chris Walsh of Vertex, Inc. discusses the growing national debt, the increasing need for federal tax reform, and the place indirect taxation may have in the American tax regime. Mr. Walsh provides an overview of indirect taxation and its relative merits vis a vis direct taxation. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.

On this edition, Bob Goulder discusses the essential elements of Value Added Taxation (VAT), how these principles are applied in the majority of industrialized countries, and the potential impact of a VAT on American taxpayers and the U.S. economy. He analyzes the relative merits of VAT as a consumption tax and objections being raised and compares and contrasts the merits of VAT vis a vis federal sales taxation. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.

On this edition, Sheldon Laskin analyzes U.S. v. Textron. Mr. Laskin outlines the court's rationale, discusses Textron in the context of other relevant litigation, the potential impact these cases may have on attorney work product principles, and best practices for taxpayers and counsel in view of current litigation trends. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.

On this edition, Martin Sullivan, Contributing Editor for TaxAnalysts® publications, discusses the role taxes may play in the ongoing health care reform debate, as Congress strives to craft a bill for President Obama's signature. Mr. Sullivan discusses the possible tax consequences of health care reform funding needs, and analyzes the merits of tax and enforcement measures that may be necessary to make the reform package viable. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Patrick Van Tiflin, Partner in the law firm Honigman Miller Schwartz and Cohn LLP, reviews elements of the Michigan Business Tax. Mr. Van Tiflin analyzes MBT performance in refining the state's Single Business Tax regime, new parameters introduced by the MBT regime, and the clarity of its principles to Michigan taxpayers. He discusses positive aspects of the MBT and also areas of concern, commenting on the potential impact of MBT litigation and what additional guidance may be needed for MBT taxpayers. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Chris Bergin, President and Publisher of TaxAnalysts®, reviews essential elements of President Obama's tax policy, the viability of his proposals, and the potential economic and social impact they may have. Mr. Bergin outlines taxation and economic precepts enunciated by the President before and since taking office, how his vision plays in Congress and with the electorate, and the results President Obama's policies may yield. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Jeff Toberer analyzes Garnett v. Comm'r, a U.S. Tax Court case challenging the established IRS position on passive loss rules. Mr. Toberer discusses the passive investment presumption, how the presumption applies or should not apply to certain taxpayer interests, and how the presumption's validity turns on key facts and circumstances related to the taxpayer's material participation. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Robert Goulder analyzes essential elements of President Obama's international tax proposals and what they could mean to U.S. companies competing in the global marketplace. He outlines what the proposed measures purport to accomplish, how the proposal's basic elements are conceived to work, and how they would change the corporate tax landscape. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Carley Roberts analyzes 2008 California tax underpayment penalty legislation in the context of historical and recent trends in state tax amnesty programs and penalty legislation. Ms. Roberts outlines related emerging constitutional and ethical concerns, how other state taxing authorities may react to California developments, and the potential impact these trends may have on corporate tax department tax reporting. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Trudy Nearn focuses on key tax awareness issues affecting same gender couples, discussing income-, estate and gift-, and property tax issues that can impact their tax liabilities. She outlines distinctions between federal and state tax concerns affecting same gender couples, and explains the importance of registering for domestic partner status for state estate and gift tax purposes. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Sheldon Laskin analyzes the Supreme Judicial Court of Massachusetts' recent holding in Capital One Bank & Capital One F.S.B. v. Commissioner of Revenue. Mr. Laskin outlines the court's rationale, the constitutional implications and the breadth and limitations of the holding's potential impact on substantial nexus doctrine. Mr. Laskin compares Capital One with other recent substantial nexus case decisions and projects the future of state tax nexus policy. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Alice Joseffer discusses cooperative efforts between the Internal Revenue Service and foreign nations to reduce tax avoidance and improve tax reporting and payment compliance. Ms. Joseffer outlines reporting requirements, describes voluntary compliance initiative parameters, and discusses transfer pricing and international treaty awareness issues. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Andrew Swain discusses tax compliance enforcement strategies being employed by the Indiana Attorney General's Office in cooperation with the Indiana Department of Revenue. Mr. Swain describes examples illustrating the breadth of non-compliance in the state, the success of criminal investigations, and criminal penalties. He also compares Indiana's tax enforcement dynamics with those of other states. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Jack Trachtenberg discusses the New York Office of Tax Enforcement and its Special Investigations Unit arm, recently established to improve voluntary tax reporting compliance through voluntary disclosure and through criminal investigations and related action. Mr. Trachtenberg outlines the strategic mission of the Special Investigations Unit, signposts of criminal and fraudulent intent, and the impact of tax preparer involvement. He also discusses tools investigators use to establish fraudulent intent and strategies taxpayers use in their defense. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Chuck Swenson describes federal and state location-based tax incentives in the context of current distressed economic conditions and constitutional issues in litigation. He also addresses tax credit and incentive opportunities the private sector overlooks and what businesses can do to take better advantage of them. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Phil Olsen discusses the recent adoption of unitary taxation of corporations doing business in Massachusetts, the rules that apply under the new regime, and how they may affect business activity in the state. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Timothy Noonan of Hodgson Russ, LLP discusses the origin and scope of New York's "Amazon Tax" law, the attendant constitutional issues, and the potential impact on sales tax reporting requirements of online retailers in New York and around the nation. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, Robb Longman of Joseph, Greenwald & Laake in Greenbelt, Md. outlines taxpayer identity theft awareness and prevention signposts, offering measures available to reduce taxpayer exposure and loss emerging from identity theft. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.

On this edition, David Rosenbloom of Caplin & Drysdale, Chartered, discusses tax policy measures the Obama Administration and Congress may, and should, pursue to meet the country's economic challenges. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc.