Tax

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  • Earn-out Sale Gets a Speedy Basis Recovery

    Guidance from the IRS allowed one partnership involved in a sale tied to earn-outs to use an alternative method of basis recovery to accelerate tax benefits. January 18, 2011

  • Payments to Foreign Issuers May Be Taxed

    When U.S. depository institutions pay the expenses of issuers of ADR programs, tax may be withheld under certain circumstances. January 10, 2011

  • Best of 2010: Tax

    The Internal Revenue Service provided its auditors with a corporate road map this year. January 6, 2011

  • Why Some Foreign Stock Purchases Flunk the Tax Code Test

    If you're planning to shelter capital gains generated by an ADR purchase, take a look at why Compaq's stock purchase seems to fail the tax code's economic substance test. January 3, 2011

  • The Elusive Definition of Research

    In trying to establish the deductibility of research activities, a lower court is ordered to take a second look at a pivotal 2009 case. December 28, 2010

  • Liquidation Without Tax Consequences

    The IRS determined that transactions completed within the same year allowed a company to avoid the typical tax hit triggered when it rescinds its incorporation status. December 20, 2010

  • Tribune's ESOP Trustee Violated Its Fiduciary Duties

    GreatBanc contended that the ESOP's purchase satisfied the intent of the publicly traded rule. But the court disagreed. December 13, 2010

  • Punitive Damages Are Not "Losses Incurred"

    State Farm's argument that the company's "statement method of accounting" controls for federal tax purposes falls flat in court. December 6, 2010

  • Tax Court Disagrees with IRS on Loss Claim

    In a case decided in early November, the U.S. Tax Court reverses an IRS decision and upholds a tax loss claimed by a company that bought a manufacturing plant from Nortel. November 29, 2010

  • Weyerhaeuser's Tax Windfall

    The conglomerate may be able to take advantage of tax benefits because "there is room for judgment" with respect to a deferred tax liability ripening into an actual liability. November 8, 2010

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