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Fox Rothschild LLP | USA | 25 Nov 2012

Financial Accounting Standards Board continues to review application of Fin 48 (ASC-70) to private companies

"FIN 48 clarifies the guidelines for accounting of uncertainty in income taxes on financial statements of enterprises per FASB Statement No. 109, Accounting for Income Taxes, and removes uncertain income tax positions from the guidance provided under FAS 5, Accounting for Contingencies."


Fox Rothschild LLP | USA | 23 May 2011

Financial Accounting Standards Board's oversight group will test a new review process for existing standards under FIN 48

The Financial Accounting Standards Board's oversight organization announced May 20 that it will test a new review process for existing standards with an analysis of FASB Interpretation No. 48, "Accounting for Uncertainty in Income Taxes."


Fox Rothschild LLP | USA | 13 Feb 2011

Reasonable cause to avoid accuracy related penalty based on advice of legal counsel rejected by Tax Court in Canal Corp. and Subsidiaries et al v. Commissioner, 135 T.C. No.9 (2010).

In Canal Corp, supra, the Tax Court recently held that a corporation's 1999 transfer of a wholly owned subsidiary to a joint venture was a disguised sale that required the company to include in capital gain the amount realized in the year of sale on its consolidated federal income tax return.


Fox Rothschild LLP | USA | 28 Nov 2010

Tax Court upholds regulations defining "underpayment" in Feller v. Commissioner, 135 T.C. No. 25 (1182010).

The Tax Court, applying the Chevron "deference" for Service issued interpretative regulations test, held that the 6664 definition of underpayment is ambiguous but that Treas.


Fox Rothschild LLP | USA | 13 May 2010

Codification of economic substance doctrine under the Health Care and Education Reconciliation Act of 2010 ("HIRE Act")

While the government has for the most part successfully attacked tax products or tax-motivated strategies that were in vogue in the late 1990s and in the 2000s, there were many cases that the Service did not get the chance to audit and thereby escaped unscathed by passage of the statute of limitations and there were also some instances where the Service suffered a judicial defeat.


Fox Rothschild LLP | USA | 9 May 2010

Second Circuit Court of Appeals reverses Tax Court and permits expensing of royalty payments incurred on sales of inventory

In Robinson Knife Manufacturing Company and Subsidiary v Commissioner, __F3d__(3192010), the Second Circuit, as set forth in the opinion of Judge Calabresi, held that the petitioner-appellant should be allowed to deduct sales-based trademark royalty payments instead of being required to capitalize such costs as was the decision of the Tax Court below, T.C. Memo 2009-9 and the government’s position throughout.

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