In a somewhat surprising display of speed, Congress has enacted, and the President has signed, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the “Act”), together with ancillary legislation containing some tax-related provisions …more

As we have reported previously, the state of California is attempting to resolve its ongoing fiscal crisis. In order to raise revenue, recent legislation has placed new strictures on the use of net operating loss carryovers to reduce California taxable income, essentially limiting the use of loss carryovers in 2010 and 2011 …more

The state of California is attempting to resolve its ongoing fiscal crisis. Meanwhile, it has announced that is delaying payment of tax refunds and may resort to issuing “IOUs” instead of cash tax refunds.more

Under current federal individual income tax law, both capital gains and corporate dividends are taxed at a reduced 15% rate. However, those reduced rates are scheduled to expire at the
end of 2010. In addition, individual income tax rates that have been taxed at a reduced rate will increase to their normal levels: the highest rate will rise from 35% to 39.6%, with other brackets increasing similarly …more

In major transactions such as business acquisitions and capital raisings, taxpayers normally pay significant transaction costs including legal, investment banking and valuation fees. Taxpayers often capitalize those transaction costs as part of the transaction and deduct them, if at all, as amortization expenses over the life of the assets involved. However, under a careful …more

In late May of 2010, the Supreme Court announced that it would not review the First Circuit’s decision in United States v. Textron, Inc. and Subsidiaries, 577 F.3d 21 (1st Cir. 2009).
In that decision, a panel of First Circuit judges had voted 3 – 2 to hold that the taxpayer’s tax accrual workpapers were not protected…more

The economic substance doctrine has existed almost as long as the income tax. It has been a judge-made doctrine, not supported by any particular statute. Variously formulated as requiring a transaction to have…more

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