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Practical US/Domestic Tax Strategies

Proven Strategies to Help You Reduce Tax Exposure for Your US Operations

Only Practical US/Domestic Tax Strategies delivers expert insight into the proven strategies your colleagues are using to minimize tax liability. Every month, Strategies delves into how domestic tax and regulatory developments will affect your organization ... and what you can do about it right now.
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Download PDF of December 2009 Issue of Practical US/Domestic Tax Strategies
19 Jan 2010

In This Issue

Planning Perspective
Recent Legislative Developments in Renewable Energy Tax Incentives
By Robert G. McElroy, Michael J. Schewel and Jonathan G. Neal (McGuireWoods LLP)    p. 2

Federal Tax
Textron, Inc. Petitions Supreme Court to Review the First Circuit’s Evisceration of the Work Product Privilege
By Douglas S. Stransky (Sullivan & Worcester LLP)    p. 3

IRS Issues Proposed Regulations on Basis Reporting by Mutual Funds and Brokers
By Gregory J. Nowak and Bryan D. Keith (Pepper Hamilton LLP)    p. 4

IRS Issues Document Corrections Program for Deferred Compensation Plans under Code Section 409A
By Leslie E. DuPuy, Daniel L. Hogans, Mims Maynard Zabriskie and Allison T. Wilkerson (Morgan, Lewis & Bockius LLP)     p. 7

Tax Court Upends IRS’s Billion Dollar Buy-in Valuation Adjustment in Veritas
By C. Cabell Chinnis Jr., Gregory L. Barton, Brian P. Trauman and John C. C. Hughes (Mayer Brown LLP)     p. 15

Highlights

Pending Legislation Offers Tax Breaks to Renewable Energy Projects
New renewable energy projects, including wind, biomass and solar, would benefit from tax incentives offered in several bills introduced in both the House and Senate in December. The incentives include Section 45 production tax credits and depreciation deductions. Page 2

Supreme Court Asked to Determine if Tax Work Papers are Privileged
Last year’s controversial decision in U.S. v. Textron permitted the IRS to view tax accrual work papers, including those that had been prepared by counsel. Textron has petitioned the Supreme Court to review the decision. Page 3

December Deadline for Avoiding Punitive Tax Penalties for Errors in Deferred Compensation Plans
A recently released IRS Notice provides employers with guidelines for correcting inadvertent errors in fashioning deferred compensation plans. Employers should review plans and make necessary changes before the December 2010 deadline to avoid significant penalties. Page 7

Court Rejects IRS Re-valuation of Intangibles
The U.S. Tax Court ruled in December that the IRS’s re-valuation of intangibles contributed by a parent company was arbitrary and capricious. The potential impact of the decision on audits and transfers of intangibles is far-reaching. Page 15

Practical US/Domestic Tax Strategies Archives
10 Jan 2008

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