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- California Department of Alcohol and Drug Programs Releases Annual Report on Prop. 36
- SACRAMENTO, Calif. -- The California Department of Alcohol and Drug Programs ADP today released an annual report completed for the Department by the University of California Los Angeles Integrated Substance Abuse Programs on Prop. 36, the Substance Abuse and Crime Prevention Act. The report, for the first time, identifies several...
- Research articles 2008-10-14
- Bids to stay in elected office taint Prop. 93
- AS A public policy, I have always opposed term limits. I have found them to be a quick fix that robs the electorate of choice. In 1990, California voters passed the most egregious form of term limits in the nation. Proposition 140 limited terms in the Legislature...
- Research articles 2008-01-31
- Bids to stay in office taint Proposition 93
- AS A public policy, I have always opposed term limits. I have found them to be a quick fix that robs the electorate of choice. In 1990, California voters passed the most egregious form of term limits in the nation. Proposition 140 limited terms in the Legislature...
- Research articles 2008-01-30
- NY Times: An Undocumented Newspaper
- Last week, in an article titled "Walking a Tightrope on Immigration," the New York Times made the fact-defying claim that the illegal immigration issue poses a risk for Republicans who appeal to voters "angry" about illegal immigration. (This is as opposed to voters "angry" that they spent good money buying...
- Research articles 2007-12-03
- New prop. regs. clarify tax deductible entertainment use of private aircraft.
- The use of private aircraft eliminates the inconvenience of commercial flights, but clients do not normally call their CPAs in midflight to inquire about the tax ramifications of taking a detour with the family on the company jet to visit Aunt Margaret. Nevertheless, it is up...
- Research articles 2007-11-01
- Lightsaber hitchhikes aboard shuttle
- The Force really is with them. The seven astronauts now in orbit on space shuttle Discovery are carrying a piece of baggage from a galaxy far, far away: a lightsaber used as a prop in the hit movie Return of the Jedi. ...
- Research articles 2007-10-30
- Increased compliance burden under new sec. 987 prop. regs.
- In September 2006, the IRS issued new proposed regulations (REG-208270-86, 9/7/06) (2006 Prop. Regs.) that provide guidance under Sec. 987 in determining foreign currency gains and losses of qualified business units QBUs operating in a functional currency other than their owner's. The 2006 Prop. Regs. are...
- Research articles 2007-07-01
- The use of government-owned vehicles for the comfort or health and welfare of personnel in deployed or remote locations
- I. Introduction: The Beginning of the Story My interest in the topic of government-owned vehicles GOVs (1) began at Gwangju Air Base, Republic of Korea. (2) It was around 2300 hours of my first night in country, when my commander woke me up from a jet-lagged stupor. He wanted...
- Research articles 2007-04-01
- Closely held employers and Sec. 409A.
- EXECUTIVE SUMMARY * Sec. 409A's definition of NQDCAs is extremely broad and potentially ensnares employment, severance and bonus arrangements. * Most deferral arrangements are subject to Sec. 409A, unless specifically excluded. * A tax adviser must determine whether an...
- Research articles 2007-03-01
- PPA '06 makes Sec. 529 tax incentives permanent.(Pension Protection Act of 2006)
- Among the provisions included in the Pension Protection Act of 2006 (PPA 06) were amendments to the Code repealing the sunset provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001 EGTRRA, to the extent they apply to the modifications to Sec. 529 qualified ...
- Research articles 2007-03-01
- TEI's comments on proposed regulations relating to section 987 qualified business units: on February 1, 2007, Tax Executives Institute submitted comments to The Internal Revenue Service on the proposed regulations relating to the Income and Currency Gain
- On September 6, 2006, the U.S. Department of Treasury and the Internal Revenue Service issued revised proposed regulations that provide guidance under section 987 of the Internal Revenue Code regarding the determination of the items of income or loss of a taxpayer with respect to a section 987 qualified business...
- Research articles 2007-03-01
- My baby 'is not a prop,' says lesbian daughter of US vice president
- WASHINGTON AFP — Having a baby to raise with her female partner was a personal and not a political move, Mary Cheney, a lesbian and a daughter of Vice President Dick Cheney, told US media. "This is a baby," Cheney said at a forum sponsored by Glamour magazine on...
- Research articles 2007-02-02
- Deferred compensation for executives under sec. 409A.(part 2)
- EXECUTIVE SUMMARY * Virtually all stock option arrangements are potentially regulated by Sec. 409A. * Sec. 409A provides an exclusive list of permitted distributions; everything else is prohibited. * The Service has blanket authority to determine permitted accelerated...
- Research articles 2006-08-01
- Allocation and apportionment of expenses for Sec. 199 purposes: for many taxpayers, calculation of the Sec. 199 deduction will require an enormous amount of work. This article focuses on one aspect of the deduction, the allocation and apportionment of exp
- EXECUTIVE SUMMARY * Sec. 861 REGULATIONS are integral to the Sec. 199 deduction when the Sec. 861 method of allocating deductions is used. * Regs. Sec. 1.861-8 provides specific allocation rules for some expenses, such as interest and R&E, and a two-step...
- Research articles 2006-06-01
- Partnership interest for services regs. offer estate planners a "bona fide" solution.
- The IRS issued proposed regulations (REG-105346-03, 5/24/05) that clarify years of uncertainty as to how a partnership interest granted for services should be taxed under Sec. 83 and subchapter K. Granting partnership interests for services is a stranger to the estate planner's toolkit. However, the clarification...
- Research articles 2005-10-01
- Forms of overseas operations.(part 2)
- EXECUTIVE SUMMARY * A partnership may allow immediate flowthrough of FTCs and losses, but is subject to complex U.S. rules when allocating income, gain, losses and taxes. * Foreign corporations are generally the preferred choice for domestic C corporations when the...
- Research articles 2005-04-01
- Forms of overseas operations: this two-part article explores the major characteristics, advantages and disadvantages of the different types of entities for conducting business overseas.(part 1)
- U.S. companies operating overseas can choose among different types of presence in a foreign country. They can (1) use a branch, (2) have an interest in a foreign entity taxable as a partnership for U.S. tax purposes or (3) create an entity taxable as a corporation for...
- Research articles 2005-03-01
- Corporate contributions to partnerships owned by shareholders.
- When the General Utilities doctrine was repealed by the Tax Reform Act of 1986, corporate liquidations and redemptions became subject to double taxation. Certain taxpayers attempted to avoid this by using partnerships in a tiered ownership structure. Shareholders would form a partnership and contribute their stock...
- Research articles 2005-02-01
- New regulations would permit cross-border "A" reorganizations for the first time in 70 years
- Introduction Section 368a(1)A of the Internal Revenue Code (1) provides that the term "reorganization" includes "a statutory merger or consolidation." Since 1935, this term has been defined to exclude mergers under foreign law. On January 5, 2005, however, the Department of the Treasury and the Internal Revenue Service issued...
- Research articles 2005-01-01
- SE tax on LLC distributable income and guaranteed payments.(self employment, limited liability companies)
- The self-employment SE tax rules oil distributable limited liability company LLC trade or business income and guaranteed payments are an everyday issue in tax practice, but there is little guidance on determining the income subject to SE tax. The SE tax rate is 15.3%,...
- Research articles 2004-10-01
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