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- Analysts learn to love the touchy-feely.
- Byline: Fiona Smith May 28, 2007 (The Australian Financial Review - ABIX via COMTEX) -- Shareholders are becoming increasingly important to the issue of employee rights. AMP Capital ranks "intangibles" as being worth 77 per cent of a company's value, which includes an ability...
- Research articles 2007-05-28
- Intangible Capital and Economic Growth
- Intangible Capital and Economic Growth; Carol Corrado, Charles Hulten and Daniel Sichel: National Bureau of Economic Research Working Paper 11948; Sept. 2006. This study provides evidence that investments in intangible knowledge capital, which includes R&D and human competency, are having a much greater impact on measures of U.S. economic...
- Research articles 2007-01-01
- Follow-up comments on cost-sharing regulations
- The following comments were filed with the U.S. Department of the Treasury and the Internal Revenue Service on October 20, 2006. They were prepared under the aegis of TEI's International Tax Committee, whose chair is Janice L. Lucchesi of Akzo Nobel Inc. This letter follows up on our August...
- Research articles 2006-11-01
- The ins and outs of sec. 197. (acquired intangibles)
- Sec. 197 covers the proper tax treatment for most acquired intangible assets. Prior to its enactment in 1993, entities that acquired another trade or business faced the heavy burden of a two-pronged test to amortize acquired intangibles. The taxpayer had to estimate the intangible asset's useful...
- Research articles 2006-10-01
- New TAM highlights issues in like-kind exchanges involving intangibles
- When corporations are considering the disposition of business assets, one of the issues that frequently arises is whether a like-kind exchange under section 1031 of the Internal Revenue Code might be available to defer gain recognition. Many businesses will have significant intangible assets, leading to an inquiry about how these...
- Research articles 2006-03-01
- Intangibles - amortization recapture and allocation of sales price.
- Tax practitioners should exercise diligence when advising clients on dispositions of Sec. 197 intangibles. The rules regarding the character of income recognized on such dispositions require detailed analysis, especially in light of the Energy Tax Act of 2005 ETA. Amortizable Sec. 197 Intangibles ...
- Research articles 2006-02-01
- TEI comments on proposed cost sharing regulations: November 28, 2005
- On November 28, 2005, TEI filed the following comments on the proposed regulations relating to cost sharing arrangements under section 482 of the Internal Revenue Code. The Institute's comments were prepared under the aegis of its International Tax Committee, whose chair is John J. Herson of Neenah Paper Inc. The...
- Research articles 2005-11-01
- Allocation of employee stock options to cost-sharing agreement.
- P is in the business of researching, developing, manufacturing, marketing and selling field-programmable logic devices, integrated circuit devices and other development software systems. P entered into a cost-sharing agreement to develop intangibles with X, its foreign subsidiary. The Agreement Under...
- Research articles 2005-11-01
- Went for cost, priced at cost? An economic approach to the transfer pricing of offshored business services
- What are the implications of the rapid growth in offshored business services for transfer pricing, the pricing of products traded between affiliated firms? I explore these implications through a case study of transnational corporations in the teleservices industry. Teleservices firms own foreign affiliates that provide inbound and outbound call services...
- Research articles 2005-08-01
- The ins and outs of related party add-backs
- Overview Historically, business performance measurement has relied on various financial measurements. The ability to efficiently manage capital structures and leverage assets is a key indicator of a successful businesses enterprise. Increasingly, to perform these functions effectively, resources must be devoted to identifying key, often hidden, assets and ensuring the...
- Research articles 2005-05-01
- Navigant International -FLYR- to Delay Filing of 2004 Annual Report on Form 10-K
- DENVER -- Navigant International, Inc. (Nasdaq: FLYR), the second largest provider of corporate travel management services in the United States based on airline tickets sold, today announced that it will delay the filing of its Form 10-K for the fiscal year ended December 26, 2004. As a result, Navigant will...
- Research articles 2005-03-11
- Assessing Assets
- Assets, the resources a company uses to carry out its business and create income, include cash, shares, accounts receivable, inventory, property, equipment and machinery, and certain intangibles like brand marks and patents, agreements, copyrights and goodwill.Any successful business must continually assess, monitor and make the best use of its assets...
- Articles 2007-07-03
- Culture club
- What do you love about your job? The challenge, the camaraderie, personal development? Companies would love to know how these intangibles--the things they can't control once they square away pay and benefits--make workers stick around and grow. We decided the best thing to do was ask people: job-seekers, working professionals,...
- Research articles 2004-12-01
- Conversion of C corporation into an LLC.(limited liability company)
- The major advantage of a limited liability company LLC over a C corporation is the absence of double-level taxation of the LLC and its members. However, the tax consequences of converting a C corporation to an LLC could have deleterious effects on both the liquidating corporation...
- Research articles 2004-11-01
- Krenzel says he won't be nervous.(Sports)
- Byline: Bob LeGere Daily Herald Sports Writer In his first start at Ohio State, quarterback Craig Krenzel directed a victory over Michigan as a 20-year-old sophomore in front of more than 100,000 fans at Ann Arbor, Mich., in one of college football's greatest rivalry...
- Research articles 2004-10-28
- Markers and Musings:The Proposed Section 482 Services Regulations
- This article was first published in The Tax Executive, November/December 2003 Mrs. Lewis expresses her appreciation to her colleagues Rebecca I. Rosenberg and Roy A. Moss for their assistance in connection with the preparation of this article. Introduction In September, the Internal...
- Research articles 2004-06-28
- The final INDOPCO regulations: a primer
- Twelve years after the Supreme Court's landmark (or nefarious, depending on your perspective) decision in INDOPCO, Inc. v. Commissioner, (1) the Treasury Department and the Internal Revenue Service have issued final regulations attempting to put the "significant future benefit" genie back in the bottle. The regulation represents a policy-level response...
- Research articles 2004-05-01
- Andrei's a shooting star
- Utahns have had a lot of fun this year with Jazzman Andrei Kirilenko. The nickname AK-47 his initials and his number trigger smiles. So did a Jazz promotion offering "Dinner with Andrei," a spoof on a popular low-budget art film. And who will ever forget his "cock-a-doodle-doo" haircuts?...
- Research articles 2004-02-07
- TEI comments on proposed section 482 services regulations: December 22, 2003
- On December 22, 2003, Tax Executives Institute submitted comments to the Internal Revenue Service relating to the propossed section 482 services regulations. The comments were prepared under the aegis of TEI's International Tax Committee, whose chair is Bruce R. Maggin of IBM Corporation. On September 5, 2003, the Internal...
- Research articles 2004-01-01
- Transfer Pricing: New Rules for Services and Intangibles.
- In September, the IRS proposed important changes to the cross-border transfer pricing rules. The proposal not only tailors existing transfer pricing methods to fit the particular shape of 'service' transactions better, but also shifts analytical emphasis away from a transaction's label and onto its economic characteristics. Greater harmony with OECD...
- Research articles 2003-12-22
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