SubChapter M Tax: IRS Notice 2010-49 - request for comments on modification of regs under 382 for treatment of non-5% shareholders:
"REQUEST FOR COMMENTS: MODIFICATION TO THE REGULATIONS UNDER � 382 REGARDING THE TREATMENT OF SHAREHOLDERS WHO ARE NOT 5-PERCENT SHAREHOLDERS
Notice 2010-49
This notice invites public comments relating to possible modifications to the regulations under � 382 of the Internal Revenue Code regarding the treatment of shareholders who are not 5-percent shareholders (Small Shareholders)."
Tuesday, June 29, 2010
SubChapter M Tax: irs notice 2010-50 - guideance under 382 for measuring ownership shifts
SubChapter M Tax: irs notice 2010-50 - guideance under 382 for measuring ownership shifts:
"Part III - Administrative, Procedural, and Miscellaneous
SECTION 382(l)(3)(C)
Notice 2010-50
This notice provides guidance under � 382 of the Internal Revenue Code for measuring owner shifts of loss corporations that have more than one class of stock outstanding, and, in particular, regarding the effect of fluctuations in the value of one
class of stock relative to another class of stock (fluctuations in value). It provides interim guidance to the effect that the Internal Revenue Service (IRS) will accept certain methodologies for taking into account or not taking into account fluctuations in value, and identifies one methodology that the IRS views as inconsistent with � 382(l)(3)(C). It also requests comments to assist in the development of future guidance. Any terms and definitions used in this notice have the same meaning as they do in � 382 and the �382 regulations unless otherwise provided in this notice."
"Part III - Administrative, Procedural, and Miscellaneous
SECTION 382(l)(3)(C)
Notice 2010-50
This notice provides guidance under � 382 of the Internal Revenue Code for measuring owner shifts of loss corporations that have more than one class of stock outstanding, and, in particular, regarding the effect of fluctuations in the value of one
class of stock relative to another class of stock (fluctuations in value). It provides interim guidance to the effect that the Internal Revenue Service (IRS) will accept certain methodologies for taking into account or not taking into account fluctuations in value, and identifies one methodology that the IRS views as inconsistent with � 382(l)(3)(C). It also requests comments to assist in the development of future guidance. Any terms and definitions used in this notice have the same meaning as they do in � 382 and the �382 regulations unless otherwise provided in this notice."
Taxation of Business Development Companies: IRS Notice 2010-33 -frivolous positions under 6702(c)
Taxation of Business Development Companies: IRS Notice 2010-33 -frivolous positions under 6702(c):
"Part III – Administrative, Procedural, and Miscellaneous
Frivolous Positions – This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code. Notice 2008-14, 2008-4 I.R.B. 310, modified and superseded.
Notice 2010-33"
"Part III – Administrative, Procedural, and Miscellaneous
Frivolous Positions – This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code. Notice 2008-14, 2008-4 I.R.B. 310, modified and superseded.
Notice 2010-33"
Sunday, June 27, 2010
SubChapter M Tax: From Deloitte's State Tax Matters
SubChapter M Tax: From Deloitte's State Tax Matters: "Multistate Tax Alerts:
Colorado reportable and listed transaction disclosure – July 1 deadline approaching
On April 2, 2009, Colorado adopted House Bill 09-1093, which requires taxpayers to disclose participation in “reportable” and “listed transactions.” Taxpayers subject to these disclosure provisions include corporations, individuals, estates, trusts, partnerships, S corporations, and other entities required to file an income tax return under Col. Rev. Stat. � 39-22-601. The new law also requires “material advisors” to disclose reportable and listed transactions and maintain a list of persons advised with respect to such transactions. Significant taxpayer and material advisor penalties are imposed for failure to comply with these requirements."
Colorado reportable and listed transaction disclosure – July 1 deadline approaching
On April 2, 2009, Colorado adopted House Bill 09-1093, which requires taxpayers to disclose participation in “reportable” and “listed transactions.” Taxpayers subject to these disclosure provisions include corporations, individuals, estates, trusts, partnerships, S corporations, and other entities required to file an income tax return under Col. Rev. Stat. � 39-22-601. The new law also requires “material advisors” to disclose reportable and listed transactions and maintain a list of persons advised with respect to such transactions. Significant taxpayer and material advisor penalties are imposed for failure to comply with these requirements."
SubChapter M Tax: From Deloitte's State Tax Matters
SubChapter M Tax: From Deloitte's State Tax Matters: "ncome/Franchise:
Connecticut: New law requires defined “captive REITs” to add back federal dividends paid deduction
H.B. 5494, signed by gov. 6/7/10. Effective July 1, 2010, and applicable to income years commencing on or after January 1, 2010, new law requires the addition of the federal dividends paid deduction by a defined captive real estate investment trust (REIT). Specifically, the new law requires captive REITs that file state corporation business tax returns to add back to their federal taxable income the amount of dividends deductible under Internal Revenue Code Sec. 857(b)(2) in determining their state net income."
Connecticut: New law requires defined “captive REITs” to add back federal dividends paid deduction
H.B. 5494, signed by gov. 6/7/10. Effective July 1, 2010, and applicable to income years commencing on or after January 1, 2010, new law requires the addition of the federal dividends paid deduction by a defined captive real estate investment trust (REIT). Specifically, the new law requires captive REITs that file state corporation business tax returns to add back to their federal taxable income the amount of dividends deductible under Internal Revenue Code Sec. 857(b)(2) in determining their state net income."
SubChapter K Tax: From Deloitte's State Tax Matters
SubChapter K Tax: From Deloitte's State Tax Matters: "Income/Franchise:
Delaware: New law requires nonresident withholding on gains from real estate
H.B. 349, signed by gov. 6/11/20. Effective for tax periods commencing after December 31, 2010, new law requires nonresident persons (corporations, individuals, or pass-through entities) that sell real estate owned in Delaware to declare and pay their estimate of the associated corporate/individual income tax due on the gain recognized from the sale before the new deed is recorded."
Delaware: New law requires nonresident withholding on gains from real estate
H.B. 349, signed by gov. 6/11/20. Effective for tax periods commencing after December 31, 2010, new law requires nonresident persons (corporations, individuals, or pass-through entities) that sell real estate owned in Delaware to declare and pay their estimate of the associated corporate/individual income tax due on the gain recognized from the sale before the new deed is recorded."
Deloitte LLP | Final Rule Changes to Investment Adviser Custody Rule, Rule 206(4)-2
Deloitte LLP | Final Rule Changes to Investment Adviser Custody Rule, Rule 206(4)-2: "Final Rule Changes to Investment Adviser Custody Rule, Rule 206(4)-2
Navigating the road ahead
On December 30, 2009, the Securities and Exchange Commission (SEC) finalized the amendments to the custody requirements of Rule 206(4)-2 (the “Rule”), under the Investment Advisers Act of 1940. The Rule is effective March 12, 2010."
Navigating the road ahead
On December 30, 2009, the Securities and Exchange Commission (SEC) finalized the amendments to the custody requirements of Rule 206(4)-2 (the “Rule”), under the Investment Advisers Act of 1940. The Rule is effective March 12, 2010."
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