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- an individual or corporation who pays a tax
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- Competently negotiating the U.S. competent authority process
- Introduction The competent authority process has received extensive consideration recently as corporate tax departments have begun reviewing their transfer pricing in light of the Financial Accounting Standards Board Interpretation No. 48, Accounting for Uncertainty in Income Taxes (FIN 48). In measuring the potential benefit of transfer pricing tax positions...
- Research articles 2007-05-01
- Installment agreements: an alternative to offers in compromise.
- The IRS expects income taxes to be paid in a timely manner, but a taxpayer may be unable to make full payment of a tax liability when it is due. While offers in compromise are extremely complex and are often rejected by the Service, Sec. 6159 provide...
- Research articles 2007-10-01
- Tax Court strikes down timely filing requirement for foreign taxpayers.
- In a January 2006 decision, the Tax Court ruled for the taxpayer in Swallows Holding Ltd., 126 TC No. 6, effectively striking down the Sec. 882 requirement that entitles a foreign corporation to take deduction against its gross income, but only if it timely files a U.S....
- Research articles 2006-05-01
- [2238] Tax Office access to taxpayer's computer delayed.
- Dec 11, 2006 (Weekly Tax Bulletin - ABIX via COMTEX) -- The Federal Court has ruled that a computer and several hard drives remain with the Australian Government Solicitor. The items had been taken from the office of a taxpayer on 8 November 2006 by ...
- Research articles 2006-12-11
- Managing the interplay between a partnership and its partners' statutes of limitations.
- Managing the statute of limitations SOL on assessment can be complicated, particularly for partnerships and partners. The SOL on partnership and partner assessments are found in Secs. 6501a and 6229a. The difficulty is determining which statute applies. A recent court case examined this issue. ...
- Research articles 2006-01-01
- Mile high turnover: Democrats, controlling both chambers for the first time in 44 years, try to dig Colorado out of a budget mess.
- Republican lawmakers watching a small group of jubilant Democrats saunter into the Colorado House of Representatives singing and strumming "When the Saints Go Marching In," may have looked out the window onto that snowy January morning and wondered if hell had frozen over. ...
- Research articles 2005-09-01
- Personal residence gain exclusion: unforeseen circumstances safe harbors.
- Under Sec. 121a and b, taxpayers can exclude up to $250,000 of the gain on the sale or exchange of their principal residence ($500,000 for certain joint returns). However, they must have owned and used the property as a principal residence for at least two of the...
- Research articles 2005-09-01
- Constitution plan falters
- DENVER - A measure that would make it harder to change the Colorado Constitution probably won't make the ballot. In fact, it probably won't make it out of the Senate, even though a majority of senators support it. The Senate gave preliminary approval Monday...
- Research articles 2005-03-01
- Budget key in legislative agenda
- DENVER - Jobs, the economy, a balanced budget and lower health care costs are top priorities for the Legislature's new Democratic leaders when the 65th Colorado General Assembly begins Wednesday. Democrats, who control the House and Senate for the first time in 44 years, say voters tossed...
- Research articles 2005-01-09
- Fiscal folly? Colorado can't claw its way out of a severe fiscal crisis because of its TABOR amendment, which has the state slashing programs while refunding taxes. Although it has its supporters, others say it has to change. And with new party control, i
- Three years after Colorado's budget began to sink, revenues have started to come back bigger than expected. That should be good news. But in Colorado, budgeting has little to do with logic, thanks to two conflicting constitutional amendments that have hamstrung state spending. ...
- Research articles 2005-01-01
- Reduce interest due IRS: favorable new rules for interest-reducing deposits
- Interest continues to accrue while a tax liability is disputed, but the taxpayer has only a few choices to limit underpayment interest. The taxpayer can continue the dispute, but if the taxpayer ultimately loses, interest will accrue from the return's original due date until the payment date.
- Research articles 2005-06-01
- Bids to alter TABOR stall in Senate
- DENVER - State senators are playing a game of political chess as constitutional amendments and taxpayer dollars hang in the balance. And with the regular General Assembly session ending next Wednesday, time is running out. A slew of bills proposing to change the state...
- Research articles 2004-04-29
- State budget squeeze tough on lawmakers
- DENVER - Sharpen your No. 2 pencil and put your thinking cap on. Now, decide which of these scenarios makes the most sense: Option A: All state sales tax refunds disappear -- forever. Option B: Guaranteed funding increases for public schools...
- Research articles 2004-02-29
- TaxACT Extends Its Free Tax-Preparation and E-File Offer to All Taxpayers Following New IRS Free File Eligibility Rules
- As new Internal Revenue Service taxpayer-eligibility rules will exclude millions of taxpayers from filing their 2005 tax returns electronically for free, TaxACT -- America's most trusted, value-priced, tax-preparation software -- today extended its free tax-preparation and e-file offer to all taxpayers using www.taxact.com.
- Research articles 2006-01-18
- Letters
- SPOUTING OFF Residential customers bear the brunt of conservation In Sunday's Gazette, water conservation is a front-page topic ("Springs water cost and rules could be better - or worse"). And again, Colorado Springs Utilities and City Council head off in the direction of charging the...
- Research articles 2003-08-29
- Recent Refund Case Highlights IRS Tactics and Informal Claim Doctrine
- Anytime a taxpayer single-handedly takes on the 1RS and comes out the victor, it's worth mentioning. Such was the case in Remedies E. Ebert v. The United States (US-CL-CT, 2005-2 USTC para. 50,495) when Ebert, a Philippines resident and widow of a U.S. military veteran, stepped into the U.S. Court...
- Research articles 2006-09-01
- New on the Books.(Special Report: Tax Planning)
- Byline: Internal Revenue Service President Bush signed the Jobs and Growth Tax Relief Reconciliation Act of 2003 on May 28. Described below are the major changes made by the new law that affect tax years beginning in 2003. ...
- Research articles 2003-11-17
- Shifting the Burden-of-Proof Rules in Federal Tax Cases
- The Internal Revenue Service Restructuring and Reform Act of 1988 was intended to simplify tax collection and administration and to better protect taxpayers from the perceived overzealous agents of the IRS. One of the law's provisions shifted the burden of proof from the individual taxpayer to the IRS in the...
- Research articles 2005-08-01
- IRS, court ruling lighten angst of long audit.(Small Business)
- Byline: Carl Grassi An audit by the IRS can be one of the more stressful events experienced by a business owner. Recent developments may provide some relief. The IRS has been implementing new ways to limit long and often costly audits....
- Research articles 2007-06-11
- The power of "except as otherwise provided": Carry forward of passive activity losses from a closely held C corporation to an S corporation
- I. INTRODUCTION: ST. CHARLES INVESTMENT CO. v. COMMISSIONER1When St. Charles Investment Co. SCI elected S corporation status, it disposed of rental properties at a loss and deducted related suspended passive activity losses PALs it previously incurred as a C corporation.2 In deducting the PALs, SCI relied on I.R.C. [sec] 469,...
- Research articles 2003-01-01
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