On Monday July 14th, the Michigan Supreme Court held in a split decision that IBM had the right to elect to use the evenly weighted three-factor formula from the Multistate Tax Compact (“MTC”) to apportion its income in calculating its 2008 Michigan taxes. The Michigan Department of Treasury argued that the Michigan legislature’s enactment of…
Summary Everyone is happy that Circular 230 disclaimers have been nixed in conjunction with the end of the Covered Opinion rules. The new Circular 230 rules covering written advice install a number of reasonableness inquiries, which utilize a new “reasonable practitioner” standard. The new principle based standards are “more straightforward, simpler, and can be applied…
Can you help your client obtain a “step-up” in a stock purchase? As a tax adviser, you may have been confronted with the following scenario: your client (P) is buying 100% of the stock of a corporation (T) from seller (S), but the purchase price far exceeds T’s basis in its assets. Since P…
