North America Tax News & Developments - Volume 10, Issue 4
Newsletter
18 August 2010
Author/s:
North America Tax Practice Group
Articles in this issue include:
- A Taxpayer Victory in the Most Recent Battle Over Documents Disclosed to Independent Auditors
- Tenth Circuit Finds No Economic Substance in Sala
- Why the IRS Needs to Give Up Stock Option Ghost in Cost Sharing Arrangements
- Calloway v. Commissioner: The Tax Court Issues the First of Two Consecutive Unfavorable Rulings in Share Lending Transactions
- The Arm's Length Standard in the Real World: The Federal Court of Appeals Decision in GlaxoSmithKline Inc.
- State Tax Developments
- Illinois Offers a Tax Amnesty Program
- Supreme Court Held Comity Barred Federal-Court Adjudication of Challenges to Certain State Tax Schemes
- Throwout Rule Withstands Constitutional Challenge in Whirlpool
- Remedies in State Tax Controversies: Fighting the Tide of Retroactive Tax Policy
- Washington Implements Key Changes to the B&O Tax: Economic Nexus and Single Sales Factor
- The First Round to the Taxpayer – Court Holds that Intercompany Transactions are Excluded in the Calculation of the Research Credit
- Special "Split-Waiver" Election Permits Five-Year Carryback Without Forfeiting NOLs to Former Consolidated Group—Calendar Year Taxpayers Have Until September 15, 2010 to Take Advantage of the New Rules
- Notice Outlines Forthcoming Entity Classification Regulations to Target Domestic Partnership Blocker Structures