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IRS emphasis on partnership audits

Landwell
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USA
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November 22 2011

Information published by the IRS shows a major change in the types of tax returns companies are fi ling due to changes in their business structures

Legislative language for Obama Administration “excess returns” proposal raises issues

Landwell
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USA
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November 22 2011

The Obama Administration recently released legislative language for fi ve revenue-raising proposals in the international tax area from its fiscal year 2012 Budget

Critical IRS policy change regarding processing and filing deadline to carryback 2010 net operating losses

Landwell
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USA
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November 22 2011

The ability for corporate taxpayers to obtain a quick refund by filing IRS Form 1139, Corporation Application for Tentative Refund, is important and can quickly increase a corporation’s cash flow in today’s difficult economy

Discussion draft released for corporate rate reduction and territorial tax system

Landwell
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USA
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November 22 2011

On October 26, 2011, House Ways and Means Committee Chairman Dave Camp released for public comment a discussion draft on revenue-neutral corporate tax reform that lowers the top corporate tax rate to 25 and adopts a territorial tax system, generally effective for tax years beginning after 2012

United States government prevails in three tax shelter cases on the same day

Landwell
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USA
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November 22 2011

One September 30, 2011, three US federal courts held in favor of the United States in separate cases involving abusive tax shelters

President Obama proposes $467 billion in tax increases to offset cost of jobs bill

Landwell
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USA
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October 17 2011

President Barack Obama on September 12, 2011 sent to Congress legislative language and analysis for the $447 billion American Jobs Act that he proposed the week earlier, asking Congress to adopt the $467 billion in revenue raisers that would more than offset the cost of the package

IRS increases scrutiny of inter-company debt arrangements

Landwell
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USA
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October 17 2011

The IRS has always been concerned with issues of thin capitalization, debt versus equity characterization and interest deductibility

Senator Reid introduces a revised Obama Jobs Act

Landwell
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USA
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October 17 2011

On October 5, 2011 Senate Majority Leader Harry Reid introduced a revised version of the Obama Administration’s American Jobs Act

Corporate tax reform hearings

Landwell
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USA
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October 17 2011

Since the 112th Congress commenced in January, the House Ways and Means Committee and the Senate Finance Committee have held more than 20 hearings to discuss principles and general issues of tax reform that could establish a framework for developing and analyzing specific tax reform proposals

US tax treaty developments

Landwell
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USA
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October 17 2011

The Senate Foreign Relations Committee on July 26, 2011 approved the new US-Hungary tax treaty and protocols to the Luxembourg and Switzerland treaties, with the recommendation that all three pacts be approved

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