Gain from selling carbon dioxide allowances didn’t generate foreign personal holding company income PLR 200825009 Mike Habib, EA IRS has privately ruled that gain from the sale of surplus carbon dioxide allowances didn’t constitute foreign personal holding company income (FPHCI) under Code Sec. 954(c). It concluded that the emissions allowances…
House Subcommittee Passes IRS Funding Bill The House Appropriations Financial Services Subcommittee this week passed a bill that would appropriate $11.4 billion to IRS for FY 2009. The bill would grant IRS budget authority to spend $5.1 billion on enforcement, $2.2 on taxpayer services, and $3.8 billion on operations. The…
Business Provisions of the Economic Stimulus Act of 2008 Mike Habib, EA The Economic Stimulus Act of 2008 contains two provisions that provide tax benefits for businesses. The first provision increases the limit up to which a business can expense property purchased and placed in service during its 2008 tax…
More disaster victims in Indiana, Iowa and Wisconsin qualify for tax relief IRS website [https://www.irs.gov/newsroom/article/0,,id=108362,00.html] Mike Habib, EA IRS has announced on its website that additional counties in Indiana, Iowa and Wisconsin have been declared disaster areas on account of recent severe storms, tornadoes and flooding. As a result, more…
Regs crack down on tax avoidance repatriations of CFC earnings Preamble to TD 9402, 06/23/2008; Reg. § 1.956-1T; Preamble to Prop Reg 06/23/2008; Prop Reg § 1.956-1 Mike Habib, EA IRS has issued temporary and proposed regs to determine the basis of certain U.S. property acquired by a controlled foreign…
Business standard mileage rate increases for last half of 2008 – other rates also rise Mike Habib, EA IRS has announced that the optional mileage allowance for owned or leased autos (including vans, pickups or panel trucks) will increase 8¢ from 50.5¢ to 58.5¢ per mile for business travel from…
<span Tax Settlements – As Seen On TV Mike Habib, EA Many Tax Relief and Tax Negotiation firms advertise on TV claiming that they can settle your tax debt for “pennies on the dollar”. Now, you, as a taxpayer must be informed of what options you have and should research…
Recap of recent state employment tax laws, developments, and changes taking effect in July Several states and localities are making employment tax changes that take effect in July. In addition, several new employment tax laws and developments have occurred recently. Here are some of the highlights from the following states:…
Appeals Court overturns oil company’s large claim of right refund Texaco v. U.S. (CA 9 6/13/2008) 101 AFTR 2d ¶ 2008889 The Court of Appeals for the Ninth Circuit has reversed a district court award of an over $100 million refund claim to a large oil company, which had sought…
Why the company car is still a valued fringe benefit for company owners and key employees A company car has long been an extremely popular “perk” or fringe benefit for company owners and key employees of medium sized or small enterprises. As this article demonstrates, this benefit yields substantial nontax…