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1. Chart Builders Bloombe Tax and Accounti The chart displav includes BNA 2 Lt 0 links to Code and Analysis l y XI Hide Row Column Add to My Foldersil Edit Restore Export to Excel f California j Colorado To save the chart click Add to Federal Constitutional Requirements Federal Constitutional Requirements 1 A state may tax out of state activities only if it can show that the A state may tax out of state activities only if it can show that the My Folders see page 1 0 activities taxed have substantial nexus with the state Nexus activities taxed have substantial nexus with the state Nexus limitations are governed by the United States Constitution under the limitations are governed by the United States Constitution under the Due Process Clause as well as the Commerce Clause The Due Due Process Clause as well as the Commerce Clause The Due P Process Clause requires a minimum connection between the state Process Clause requires a minimum connection between the state The ch art di spl ays with an and the person property or transaction being taxed The Commerce and the person property or transaction being taxed The Commerce Clause requires that an activity have substantial nexus with the Clause requires that an activity have substantial nexus with the 1 state in order to be taxed Quill Corp v North Dakota 504 U S state in order to be taxed Quill Corp v North Dakota 504 U S option to Export to Excel 98
2. Your social secunty number 0 Ss Beginning Your first name kud Spouse s first name a Present home address number and street or P O Box number a City town or post office Check il address Exemptions initial Lastname initial Lastname Forsign outside US E Country Filing Status 1 1 500 Single 30 1 500 Married filing separate Complete Spouse SSN 2 e E 3 000 Married filing joint Filing Information CAUTION Form 40 is machine read Follow these rules when filling in the form 7 1 Round amounts to the nearest whole dollar enter as 100 00 2 File the laser printed original no substitutions such as a photocopy or PDF are acceptable Some fill in data will be automatically formatted to government specifications and cannot be changed This indudes the use of specific fonts commas and or decimals negatives in parentheses and rounding of whole dollar amounts Spouse s SSN il joint return State ZIP code P CHECK BOX IF AMENDED RETURN 6 m AL39 4e Q 3 000 Head of Family with qualifying person Profiles 5 Wages salaries tips etc list each employer and address separately A Alabama tax withheld 5a e 5a o B Income Profiles are reusable files containing contact and other pertinent information Click the New Profiles 93 button to create a new profile Select a profile for Entity Fiduciary Individual or Preparer and click OK To appl
3. 18 U S District Courts Ohio 28 U S Tax Court 48 State Tax Supreme Court Cases 128 State Tax Lower Court Cases 18 Executive Compensation Cases 79 AFTR2d Para 97 338 79 AFTR2d 97 442 79 AFTR2d Para 97 338 Unempl Ins Rep CCH P 15 136B 1996 U S Dist LEXIS 2274 14 Search Results Toolbar The search results toolbar resides on top of the screen on the search results display Search Within Results Use this link to refine a search and limit the results by adding additional search terms or criteria available only when using the Advanced Search option Go to Hit Navigate to and through the search result document s Results in Toggle among the content categories included in a set of the search results Add to My Folders Search Click to add a search string to a folder See page 10 for additional information Print Click the Print icon 29 to launch the print function Add to My Folders Document Click to add a document or chart to a folder See page 10 for additional information Share Send a document link to other Bloomberg BNA Tax and Accounting Center subscribers Split Screen Simultaneously view a category s search results and the full text of a selected document 4 Go to Hit P Results in U S Income 3 State Tax Portfolios 1 Sales amp Use Tax Portfolios 1 State Guides amp Navigators 2 News 54 Laws Regs Agency Docs 37 Cases 21 Go Browse Content
4. Slump Posted Feb 10 2015 19 03 AM EST Robert Carroll EY Treasury Releases Internal Use Soltware Regulations By Stephanie shell Condon and Jeff Issije dated Tuesday February 10 2015 Number 27 Male HIGHLIGHTS Teff Malo eI PTT biel Ryan ULC IRS Watching for High Risk FATCA Cases as Implementation Gears Up The IRS will be watching for high risk cases of possible violations of the Foreign Account Tax Compliance Act Large Business amp International Division Commissioner Douglas O Donnell says In a discussion with reporters on 4 renee of LERT priorities O Donnell says the IRS is expecting the majority of FATCA information to start arriving In the fall and ts still organizing its overall exam focus More s O Donnell also says the IAS faces several challenges as country by country reporting requirements come Into play In 2015 Including how ta use the information produced Mora The UK s Gopgle Tax First Thoughts By Paul Rutherford INTERNAL REVENUE SERVICE Faul Rutherford DLA Piper From the Editors s eneral Explanations of the Administration s Fiscal Year 2016 Revenue Proposals Green Book 2015 Outlook Tax Accounting and Pensions 2015 Outlook Tax Accounting and Pensions PDF versia Final Foreign Credit splitter Rules Praised as Reasonable Approach New final IAS rules T D 9710 on foreign tax credit splitter transactions win pralse from practitioners as a rea
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7. 1381 054 Transfer Of DIEC Te Trusts And Continued Contractual Relationships Are Taxable Gifts Prede Hak b Rev Rul 1981 054 Transfer Of DISC Ta Trusts And Continued Contractual Relationships Are Taxable Gifts Source Rev Pul fil 54 idfil 1 C E 476 Referencer LAC 2501 25127 b Re 25 2511 2 25 2512 8 252511 1 Summary Corporation H is a domestic manufacturing business organized in 1972 which selk ome hall of its products outside the ried States All the stock of M js pared in equal shares by individuals A E and C In January 1978 in order to maximize the profitability of export business of M A B and C formed a DISC Each of them transferred 1 000 in cash to the DISC in exchange for equal shares of DISC Immediately thereafter A B and made gifts of all of their DISC stock ta three irrevocable trusts crested for the benefit of their respective minor children Each of the spouses of A B and C was designated as sole trustee of the trust for their respective children The trustees of the three trusts were given full power to deal with the trust assets as f they opmed those asseta Guiright After the DISC stock was transferred ta the trust and the DISC agreed that the DISC would be agent of M with respect to His export business fur which The DISC is to be paid a commission 4 B and C each made taxable gifts of shames in the DISC ta the trusts created for their children upon the transfer of those shares The value a
8. I R S regulations and more Source Documents 22 Full text of primary source documents AI VS IE is i l wenden 23 Portfolios Fast Answers Green Incentives Navigator and more Practice Tools 2ssnnnnnnn 24 Federal and State Practice Tools increase the efficiencv of a tax and accounting practice and include chart bullders tax calculators transactional diagrams client letters and more Withholding Tax Chart Builder 26 Compile a chart with commentary to find both withholding tax rates under a source country s domestic law and the applicable income tax treaty rates when paid to the country s treaty partner investor countries State Income Sourcing Tool 34 Source receipts and compute the sales factor when apportioning business income to the state Tax FOrmsS 00cee eee e eens 37 Federal and state interactive tax forms Information on how to print a single or multiple documents User Name and Password to get started The Tax Center App offers Tax and Accounting subscribers easy on the go access to federal state and international tax analysis news integrated source material and advanced search features all on the Android iPhone or iPad devices Go to www bna com btac app for information on how to download the free Bloomberg BNA Tax Center App iPad iPhone The Tax Center App is available on iPhone and or iPad devices Installation of iTunes is required to
9. Royalties 30 Investor Countries Jurisdiction Strategic Dividends Portfolio Dividends Specific Kinds of Interest xi Interest Generally Royalties xi United States of America No treaty No treaty No treaty No treaty No treaty Albania Xi United States of America 5 15 0 0 0 Austria Article 10 Article 10 Article 11 Article 11 Article 12 The 5 rate applies where the recipient of The 15 rate also applies to all dividends The treaty makes no special provision for The exemption does not apply to A 10 rate applies to royalties paid for the the dividends is a company that holds a paid by a RIC specific kinds of interest so that the rate that use of or right to use cinematograph films percentage interest of at least 10 in the applies is the rate for interest generally a an excess inclusion with respect to a or films tapes or other means of reproduction voting stock of the company distributing the The 15 rate also applies to dividends paid residual interest in a real estate mortgage used for radio or television broadcasting dividends by REIT to an individual holding less thana The exemption does not apply to investment conduit or 10 interest in the REIT Other dividends Royalties are defined as The 5 rate does not apply to dividends paid paid by a REIT may be taxed by the United a an excess inclusion with respect to a b interest that is contingent interest of a Tabs organizing the information and commentary are added to the E
10. Similarty liquidation or disposition could cause foreign taxes to be suspended permanently unless all of the related income is distributed or otherwise recognized beforehand or as part of the transaction he said PwC s Rosenberg pointed out a change In the IRS s analysis of loss sharing splitters She sald the new final regulations explicitly state that a usable shared loss includes only a loss that the loss generating group could have used itself in a prior or current taxable year In other words she said the regulations now make clear that a group s ability to potentially use its own loss in a future taxable year is irrelevant in determining amp usable shared loss Rosenberg sald that does raise the question however of whether the IRS and Treasury think that the temp regs definition of usable shared losses included losses that might be carried back to prior years Many thought that the temporary regulations didn t contain such a rule the Pred practitioner an International tax specialist sald She also pointed out that the IRS finalized temporary regulations under tax code Section 704 as part of the Feb 9 package These Section 704 regulations are relevent to the interpretation of partnership interbranch payment splitters under the 909 regs Rosenberg said T D 9710 will be effective when it appears in the Federal Register Feb 10 To contact the reporter on this story Alison Bennett in Washington at abennettaib
11. State County City or Street Address based on your search criteria Street Address 2 Enter your search criteria into the form field s 3 Click the Search button or press Enter to see the results for your search ES Have questions Contact us toll free at 1 800 372 1033 PR USA Search using a zip code Search New Rates Favorites Rates Exporter and or any combination of state county city or strastadabeee Fansite seach results by State Zip Code A COLORADO 2 9000 ARAPAHOE 1 0000 DENVER 3 6500 When searching by zip Ss ee a JFostalcoce a6 de try ruse the zip 4 COLORADO ARAPAHOE DENVER 80110 as there can be different tax sierra Pe rates for the towns within I f COLORADO 2 9000 ARAPAHOE 0 2500 ENGLEWOOD 3 5000 that zip code For example State at city Postal Code see the difference in tax Street Address COLORADO ARAPAHOE ENGLEWOOD 80110 rates for zip code 80110 Search results by State Recent Items 10 B B COLORADO 2 9000 ARAPAHOE 0 2500 LITTLETON 3 0000 To create Favorites A state County p Postal Code click the Star icon wre DENVER ARAPAHOE CO USA 80110 COLORADO ARAPAHOE LITTLETON 80110 CO USA Search results by State To view Favorites SK CAN 2 COLORADO 2 9000 ARAPAHOE 0 2500 SHERIDAN 3 5000 click the Favorites tab z NU CAN COLORADO ARAPAHOE SHERIDAN 80110 YT CAN Search results by State AB CAN B COLORADO 2 9000 DEN
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13. 03 H U S GAAP Navigator 0 Payroll 411 News and Commentary 33 Laws Regulations Agency Documents 31 Fast Answers 2 Cases and Decisions 8 Practice Tools Are individuals subject to the net investment income tax 28 Tax Forms amp Guides What are some examples of items that are included in net 40 Indexes and Finding Aids investment income 0 Events amp Training What are the threshold amounts at which a taxpayer with net investment income becomes liable for the net investment income tax What is modified adjusted gross income for purposes of the net investment income tax What is the net investment income tax Practice Tools Client Letter 3 8 Medicare Tax on Net Investment Income Client Letter Proposed Letter Concerning Net Investment Income Tax Related lt GO gt Pages Net Investment Income Tax Application to Estates and Trusts Passive Activity 15 lt GO gt PAGES Topical lt GO gt Pages display editor selected content specific to the topic searched Click the blue arrows b to display explanatory information and linked Bloomberg BNA Portfolio and Tax Practice content related I R C sections regulations practice tips and state and international considerations lt GO gt Pages are continually updated and reflect standard tax topics and the evolving industry wide hot topics lt GO gt Pages Go row onten B D adito Ms Folders So Share JE Split Screen lt GO gt Pages gt Estat
14. E open i level open all B close ilevel close all Split Screen Check to add to print selection list Transactional Diagrams B Business B Estate and Gift C Rev Rul 1971 443 Gift Of Property To A Corporation Is A Gift Of Future Interests And Proportionate Interest Qualifies For Marital Deduction C Rev ption of Stock is a Meaningful Reduction of Shareholder s Interest and If Not Essentially Equivalent to a LIRev Rul 2014 002 Situation 7 Tax Characterization of the Payment Received Pursuant to the National Mortgage Settlement Deceased Borrower 7 of 7 Individual International Trust Click Search All to display a pre loaded Advanced Search template Advanced Search You are searching Select one or more of the following optional criteria Practice Tools to limit your search Transactional Diagrams Search term s i ETD Reset Form Cancel 6 Fields Show shared fields only O Show fields from all selected collections Choose a field V ADD TO SEARCH Choose a field enter search terms for the field then click Add to Search Limit by date e Omm a Ex mm dd yyyy Ex mm dd yyyy SEARCH Reset Form Cancel Tranactional Digarams continued A visual depiction of the complex fact is displaved with linked Source and Reference information Transactional Dingrame im Erowge L ant ik skin Ma ihian Sy ihaw n Sole baten Transactional Diagrams gt Estate and Gift gt Rev Rul
15. EBC 1513 2012 Supreme Court of the United States Solorio v United States 483 U S 435 107 S Ct 2924 97 L Ed 2d 364 1987 Cited See als Dissenting Opinion 6 show All Supreme Court of the United States Bob Jones Univ v United States 461 U S 574 103 S Ct 2017 76 L Ed 2d 157 1983 Dissenting Opinion Cited See Result Filters Results Per Page SNOW 50 Supreme Court of the United States Bob Jones Univ v United States 461 U S 574 103 S Ct 2017 76 L Ed 2d 157 1983 Sort By Supreme Court of the United States North Georgia Finishing Inc v Di Chem Inc 419 U S 601 95 S Ct 719 42 L Ed 2d 751 1975 Description of BCite Indicators Supreme Court of the United States bS United States v Jackson 390 U S 570 88 S Ct 1209 20 L Ed 2d 138 1968 17 NEWS amp COMMENTARY The Tax and Accounting Center offers Daily Tax Report Index many ways to keep up with the latest Daily Tax Report Highlights tax and accounting news Haan prea Click the Daily Tax Report tab to access the aie l ian Line daily report see page 19 Tax Legislation Comparison Find BNA Insights in the News amp IRS Practice Adviser Report Commentary frame BNA Insights are Green Incentives Monitor authored by Tax amp Accounting experts and offer analysis of key legal legislative regulatory and business developments with an emphasis on s BNA Insights pr
16. Estate Sme Sales Intermstioal Transfer Accounting Tax Practice Payroll More al Aepot Benefits Flanniraj l o Pricing Tapez Practice ress DAILY TAX REPORT Daily Tax Report Home is 20 Officials Pledge Ongoing Work on Profit Shifting Information Exchange IRS Sets QZAB State Allocation Limits Russia Faces Battle Over Billions in Dil Taxes After Crude Slump Daily Tax Report Highlights u Daily Tax Report Index a Daily Tax Report Highlights u Weekly Report Index Tax Legislation Comparison IRS Practice Adviser Report Green Incentives Monitor u BALA Insights u Tax Management Menarandurn index Compensation Planning Journal Index Estates Gifts and Trusts Journal Index u Financial Planning Journal Index Real Estate Journal Index Sign up for email updates Search News b Commentary FROM THE EDITORS s What s New u Mew Bloomberg BMA Chart ari Tax gees in FY 2016 Administration Budget a Hoomberg BNA Summary of H R 5771 Tax Increase Prevention Act of 7014 Client Letter on the Tax Increase Prevention Act of 3014 H R 5771 s 2015 Inflation Adjusted temiz and Katas Bloomberg BNA Federal Tax Blog Special Report Net Investment In wne Tax Sues Key GO Pages 4C4 Employer Responsibility REPS Bevelamwmnents Capitalization Regulations u FATCA Same Sex Marriage 2 Summary Charts Tax Reform Tax Lien Purchasers H
17. HIN Delete EH I R C Conformity Test chart Tax and Accounting Center 02 11 2015 Item Options O Edit Item Details Delete Duplicate Create New Move to Folder Go To Item Edit Chart SEARCH Textsize O A ABA HISTORY SAVED SEARCHES Access search templates from the search box on the banner H il This Collection This Portfolio Quick Search A ADVANCED SEARCH GUIDED SEARCH GOTO Search all content included in your subscription When working in a collection or Portfolio the banner displays the added option to search in IELI a ie eC Meso Select an option and enter search terms in the text box Click SEARCH Advanced Search The Advanced Search template is most flexible when structuring a search Choose specific collection s to search in with options to use fields search operators and or date restrictions Search Fields Add search fields to limit the range of a 1 In the Fields frame choose to Show 4 Enter or click ADD TO SEARCH search and increase the relevance of the shared fields or Show fields from The search term s are added to the search results The searchable fields are all selected collections search string in the Search Term s specific to the collection s being text box searched and multiple fields can be 2 Select a field from the Choose a field searched simultaneousiv drop down menu After the collection s are selected use 3 Enter your search terms in the te
18. Recent Cases Reported or by IRC Section Hot Topics Accounting a Backup Withholding Corporate Inversion Corporate Reporting Requirements Estate Tax a 14 Evasion u Tax Legislation a Tax Shelters Recent Topics Customize All Recent Topics TaxCore Home Page Key Features Key Tax seues in Congress Regulatory Watch Supreme Court Docket Watch Docket Watch Archive Analysis amp Perspective Interviews Congrega gow PDF Archives Courts Customize All Courts Federal Statutes Customize All Federal Statutes States Customize All States Countries Customize All Countries Electronic Commerce Law Fa dral Dale Tax JEompansatian amp Estate Stata Sake amp Intermiational Transfer Accounting Tax Practke Payroll Fiori All B Report Manning Ua L ig saias Practice Areas a Welcome Set as My Home Page Search this tab February 10 2015 CI Find by Page Number Daily Tax Real Time BNA INSIGHTS All BNA Insights TTGEN Tax Reform Business Barometer Views on the Prospects for and Key Aspects of Federal Tax Reform By Lynda K Walker and Robert Carroll G 20 Officials Pledge Ongoing Work on Profit Shifting Information Exchange Posted Feb 10 2015 1 12 PM EST IRS Sets QZAB State Allocation Limits Posted Feb 10 2015 10 57 AM EST Russia Faces Battle Over Billions in Oll Taxes Alter Crude
19. Sec 1 Tax Imposed B Chapter 1 Normal taxes and surtaxes Sections 1 to 1400U 3 All BNA Portfolios Fast Answers Ej Subchapter A Determination of tax liability ae 2 ke Sections 1 to 59B 1 a Married Individuals Filing Joint Returns And Surviving Spouses g Part I Tax on Individuals Sections 1 to 5 There is herebv imposed on the taxable income of e Sec 1 Tax Imposed B 1 a Married Individuals Filing Joint amp b Returns And Surviving Spouses 1 a 1 1 b Heads Of Households ted individual defined i on 7703 wh k inal ointi ith hi d fe amord Individuals Fin n pee i individual as defined in section who makes a single return jointly with his spouse under section Other Than Surviving Spouses And Heads Of Households 1 d Married Individuals Filing amp aiena Separate Returns 1 a 2 B i e Estates And Trusts B 1 f Phaseout Of Marriage Penalty In every surviving spouse as defined in section 2 a a tax determined in accordance with the following table ry g sp P g 22 ANALVSIS List of Portfolios Chapters Each tab has an Expert Analysis frame containing a topical list of subject specific content Bloomberg BNA Expert Analysis is written by a network of the world s leading tax authorities Fast Answers Federal Tax U S Income Portfolios Indexes Keyword IRC s Income Tax Accounting C Corporations Compensation Planning
20. See ADMINISTRATIVE ADJUSTMENT REQUESTS AARs ABANDONMENT ABATEMENT ABUSIVE TAX SHELTERS See TAX SHELTERS DAILY TAX REPORT Daily Tax Report Home G 20 Officials Pledge Ongoing Work on Profit Shifting Information Exchange IRS Sets QZAB State Allocation Limits Russia Faces Battle Over Billions in Oil Taxes After Crude Slump Daily Tax Report Highlights NEWS amp COMMENTARY Daily Tax Report Index Select a Different Index ACCELERATED COST RECOVERY SYSTEM ACRS See a so DEPRECIATION DEDUCTION ACCELERATED DEATH BENEFITS See a so DISTRIBUTIONS UPON DEATH LIFE INSURANCE ACCELERATED DEPRECIATION See DEPRECIATION DEDUCTION ACCIDENT AND HEALTH PLANS See ACCIDENT INSURANCE ACCIDENT INSURANCE See a so HEALTH INSURANCE WELFARE BENEFIT PLANS Main discussion TM 389 Age discrimination TM 389 XIV A Appeals process for coverage determination and claim denials TM 389 XIXAZ Arbitration in group plans TM 365 1X E Archer MSAs See HEALTH SAVINGS ACCOUNTS Bankruptcv Code TM 389 XIV F Cafeteria plans See CAFETERIA PLANS subheading Medical benefits Choice of entitv TM 700 XII B 4 Church plans TM 372 IV Claims procedure for group health plans DOL Regs TM 374 11 E 5 Advanced Search Select collections to search from the categories below then use the search form to perform vour search Choose collection s to search Expand All Collapse All Select All Clear Se
21. TAX GUIDE Tour Essential Desk Ratearence Indexes TAX FORMS amp GUIDES Tax Farm Interactive Federal Tax Forms PDF Tax Prep Guides 2014 x Tax Prep Guides Archive Federal Tax Guide Federal Tax Calendar PRACTICE TOOLS Tables Charts amd Lista Quick Tax Reference Tax Cabculators Client Letters Elections amp Compliance Statements c Tran eti ial Diagrams s Portfolla Working Papers Tax Practice Series Aids SOURCE DOCUMENTS Laws amp Regulations Internal Revenue Code Current Index s Internal Revenue Code Archive Treasury R gulations Index ii Proposed rexsury Regulations s Tax Legislation Agency Documents Treasury Decision Preambles IRS Document IRS Publications Circular 330 CPs TSP Papers MSSP Audit Guikkelines Cases Federal Tax Casas Tax Court Rules Court of Federal Claims Rules ERISA Health Care B Labor Source Material Excise Tax Source Material Search Source Documents it EVENTS amp TRAINING Upcoming Live Seminars March 2015 Current U S Tax Planning for Foreign Controlled Companies March 9 10 2015 San Frandisco LA gt Intraductian t US International Tax March 16 17 2015 San Francisco CA Intermediate U 5 International Tax Update March 14 20 2015 San Francisco GA SITE WAP FHETEEEALES ME ALY TES ACCOUNT PROFILE Tax and Accounting EJ Sign up fer email up
22. abroad The following is a general summary of the rules for excluding income earned and costs paid on your behalf while you were abroad Types of Exclusions Qualifying individuals are entitled to different types of exclusions under the tax law against income received while working abroad Among these are the following i a foreign earned income exclusion ii a housing cost amount exclusion and iii an exclusion for employer provided meals and lodging G open i level open all close tlevel close all fiz Split Screen C Corporation Engagement Letter Form 1120 and state return s m ate Engagement Letter Form 706 or 1041 and state return C Exempt Organization Engagement Letter Form 990 O Exempt Organization UBIT Engagemenk Letter Form 990 T and state return CJ Exempt Organization with UBIT Engagement Letter Form 990 990 T and state return C Gift Tax Return Engagement Letter Form 709 and state return Cl Individual Engagement Letter Form 1040 and state r return s m ngagement Letter Fa gt CILLC Engagement Letter Fd Q ngagement Letter Fq O Partnership Enqaqemen Cs Corporation Engagement i i wanes Nee OTr ngagement Letter I Corporation Engagement Letter Form 1120 and state return s Firm Letterhead l Corporation Name c o Contact Name s Corporation Address Corporation City State Zip Code Date Dear Salutation s and Contact Name s Thank you for
23. depends on you and your business E Partnerships P y y e The cash method used by most individuals and many small businesses with no inventories Corporations other S Corporations than S corporations and corporations with gross receipts of 5 000 000 or less partnerships with a corporation other than an S corporation as a partner and tax shelters are generally precluded from using this method C Corporations i oe ni e The accrual method required for most businesses that maintain inventories Qualifying small business taxpayers Compensation Planning with gross receipts of 10 000 000 or less and small businesses with gross receipts of 1 000 000 or less are A r exempt Income Estates and Gift Taxation e A special method for certain items of income and expense Foreign Taxation s A method that combines elements of any of the above I welcome the opportunity to meet with you to evaluate your personal situation and help you create an accounting method that will work for your company and be favorable in the eyes of the IRS Please contact me to set up a complimentary one hour consultation to discuss your needs and how I can help you Sincerely yours Client Letters continued The Client Explanatorv Letters contain links to Relevant Code Sections amp B B Ho ODEBBEBB Client Explanatorv Letters open 1 level open all close 1levell close all Split Screen Check to add to print selection list Client Expla
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26. initially returned by categories U S Income Portfolios State Tax Portfolios etc Click the relevant category to view the document s for each category list Results for retail leas Your search returned 119 documents Click on categories below to view search results Search Results for Cases and Decisions are organized by court and are sequential by date within each court grouping There is also an option to display search results by relevance 3 U S Income Portfolios 1 State Tax Portfolios 1 Sales amp Use Tax Portfolios 2 State Guides and Navigators 54 News and Commentary 3 Laws Regulations Agency Documents 21 Cases and Decisions Simultaneously view the Search Results list and the full text by using the Split Screen option Click Full Screen to toggle back to the full screen display 303 West 42nd Street Enter Inc v IRS Search Options Edit Search Within Results Add to My Folders Clear 4 Go to Hit gt Results in U S Income 3 State Tax Portfolios 1 Sales amp Use Tax Portfolios 1 News 54 Laws Regs Agency Docs 42 Cases 22 amp p Add to My Folders G Share E Full Screen Results for retail leas Check to add to print selection list E Full Screen 303 West 42nd Street Enter Inc v IRS THIS CASE CITED IN i Cases and Decisions by date within court 22 documents gt United States District Court for the Southern District of New York Show results by relev
27. 49923 at Geographic Soc v v California State Bd of Equal p 2340 69933 Natl Geographic Soc v v California State Bd of Equal 430 U S 551 1977 Natl Bellas Hess Inc v Illinois Dept of Rev 430 U S 551 1977 Natl Bellas Hess Inc v Illinois Dept of Rev 386 U S 753 1967 386 U S 753 1967 A For sales and use tax purposes the substantial nexus requirement is For sales and use tax purposes the substantial nexus requirement is To print the chart export it interpreted to mean in part that a business must have a physical interpreted to mean in part that a business must have a physical 1 n n presence in the state before the state can require the business to presence in the state before the state can require the business to F i collect and remit the state s tax Therefore in order to survive collect and remit the state s tax Therefore in order to survive to Excel and pri nt USI Ng you r scrutinv under the Commerce Clause the obligation to collect a scrutinv under the Commerce Clause the obligation to collect a 1 state s use tax may be imposed only on a seller that has a physical state s use tax may be imposed only on a seller that has a physical browser S print function l presence in the state Physical presence may be established in many presence in the state Physical presence may be established in many ways including establishing an outlet or sales location a warehouse ways including establishing an outlet o
28. AND NAVIGATORS Choose a field enter search terms for the field then click Add to b V ACCOUNTING POLICY amp PRACTICE PORTFOLIOS Search gt W U S GAAP NAVIGATOR IZIPAVROLL ADMINISTRATION GUIDE 1 NEWS AND COMMENTARY O Limit by date LAWS REGULATIONS AGENCY DOCUMENTS CASES AND DECISIONS No Date Restrictions V O From e To PRACTICE TOOLS Ex mm dd yyyy Ex mm dd yyyy TAX FORMS INDEXES AND FINDING AIDS EZD Reset Form JEVENTS amp TRAINING STATES Search Operators 23 icion A Use Practice Tools to reduce research Tables Charts and Lists and preparation time Practice Tools are o available on all tabs but Transfer Pricing Quick Tax Reference Practice Tools include chart builders Tax Calculators checklists working papers and more Client Letters Click a link to open a tool Elections amp Compliance Statements Transactional Diagrams Search selected individual Practice Tools Portfolio Working Papers using the Advanced Search template ee Advanced Search Select collections to search from the categories below then use the search form to perform your search Choose collection s to search Select one or more of the following optional criteria Expand All Collapse All Select All Clear Selected to limit your search Collections gt _JEXPERT ANALYSIS Search term s gt 1 JNEWS AND COMMENTARY ETD Reset Form b JLAWS REGULATIONS AGENCY DOCUMENTS EJPRACTIC
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34. Exchange Traded Options Investment Tax Credit The Low Income Housing Credit Books amp Treatises Research Credit Other General Business Credits s PLI Treatises General Business Credit s Getting the Deal Through Minimum Tax Credit Refundable Credits s Section 409A Handbook Computation of Tax Individuals Computation of Tax Corporations Search Expert Analysis Estimated Tax Self Employment Tax SECA Alternative Minimum Tax on Noncorporate Taxpayers Alternative Minimum Tax Corporate Taxpayers Tax Accounting Tax Practice and Procedure Partnerships S Corporations C Corporations Compensation Planning Advanced Search Select collections to search from the categories below then use the search form to perform your search choose collection s to search Select one or more of the following optional criteria Expand All Collapse All Select All Clear Selected to limit your search Collections v I IEXPERT ANALYSIS B Search term s gt FAST ANSWERS GZS Reset Form W U S INCOME PORTFOLIOS b V FEDERAL EXCISE TAX NAVIGATOR b V FEDERAL ADVISERS b W BOOKS amp TREATISES b MESTATES GIFTS AND TRUSTS PORTFOLIOS v TAX PRACTICE SERIES Fields V FOREIGN INCOME PORTFOLIOS b V TAX TREATIES ANALYSIS Show shared fields only Show fields from all selected b INTERNATIONAL GUIDES collections P EA No fields available ADD TO SEARCH SALES AND USE TAX PORTFOLIOS v STATE GUIDES
35. Tax and Accounting Retirement Savings amp Planning Required Minimum Distribution RMD Required Minimum Distribution RMD for Current Year Beneficiarv Required Minimum Distribution Companv Stock Distribution Analvsis Calculator 72 t Distribution Impact Roth vs Traditional IRA Roth IRA Calculator Roth IRA Conversion Traditional IRA Calculator Individual 401 k Contribution Comparison Pension Plan Retirement Options 401 k Savings Calculator Retirement Plan Withdrawals Retirement Pension Planner Enter vour filing status income deductions and credits and we will estimate vour total taxes Based on vour projected withholdings for the vear we can also estimate vour tax refund or amount vou mav owe the IRS next April 27 Client Letters PRACTICE TOOLS Client Development Letters Client Explanatory Letters and Client Engagement Letters Tables Charts and Lists can be customized and used for client communications Quick Tax Reference Client Development Letters are designed specifically to generate additional revenue Tax Calculators Client Explanatory Letters are sample letters that can be used to answer client questions and create a detailed explanation of a tax issue Elections amp Compliance Statements Client Engagement Letters provide details of how to compose effective agreement letters Transactional Diagrams with your clients Portfolio Working Papers Tax Practice Series
36. VER 1 0000 DENVER 3 6500 COLORADO DENVER DENVER 80110 MB CAN Sales and Use Tax Rate Finder continued New Rates View all tax rates published during the previous 30 days in the United States and Puerto Rico To view the latest rates for your favorites only check the Only Favorites checkbox Click the Future Rates tab to view forthcoming rates Search New Rates Favorites Rates Exporter New Rates O Only Favorites A United States Canada ZIP Code ZIP Historical Rates Future Rates Date Range To State County City 10 04 2015 amp Earliest data available is 1 1 2012 States 0 Street Address Recent Items USA 80110 County 2 sine feoumw a ive e escinton a revue Newt fective Da RANDOLPH SALES ALABAMA ALABAMA Rates Exporter RANDOLPH USE 11 03 2015 A No data available in table A COUNTV TAX 1 0000 2 0000 11 01 2015 COUNTY TAX 1 0000 2 0000 11 01 2015 Export tax rate data automatically at scheduled intervals or manually at any time Search New Rates Favorites Rates Exporter Scheduled Export Run the export on a schedule with the settings below Jurisdiction States Edit your states list Your currently selected states are COLORADO Favorites See favorites You currently have 2 favorite jurisdictions Note Canadian Favorites are not included in Rates Export Schedule You are set up to run your schedule every week on Monday with you
37. a C Rhode Island C South Carolina o Receipts from Cloud Computing or Software as a Service SaaS Transactions LI Special Industry Receipts Banks and Financial Services Companies C Special Industry Receipts Construction Contractors C Special Industry Receipts Telecommunications and Ancillary Services mi Special Industry Receipts Trucking Companies LI South Dakota LI Tennessee O Texas CJ Utah O Vermont O Virginia O Washington C West Virginia LI Wisconsin C Wyoming State Income Tax Sourcing Evaluator continued Each categorv specific screen displavs a customized list of questions to be answered Click Save Answers to save the project whether the answers are all completed or not The Categorv frame at the top of the page displavs a count of the number of answered questions vs the total number of questions for each categorv Use the drop down menu to toggle among the selected categories Export Questions Import Answers To answer the Project category questions in Excel and then import them back into the Evaluator Click Export Questions Only files in the xis Excel 2003 and higher or xisx Excel 2007 and higher versions will work Only the answers can be changed in Excel Note changes to questionnaire answers from the imported Excel file will overwrite current answers in the project In Excel mark your answers with a single x character Leave unanswered questions blank The number of ques
38. actical implications and emerging trends Tax Management Memorandum Find links to tax journals and their indexes in the Index News amp Commentary frame Compensation Planning Journal Index From the Editors Estates Gifts and Trusts Journal To provide a quick reference for high profile topics Index Bloomberg BNA Tax amp Accounting editors create and Financial Planning Journal Index compile specialized reports hot topic microsites Real Estate Journal Index research pages and summary documents Sign up for email updates Search News amp Commentary FROM THE EDITORS What s New New Bloomberg BNA Chart on Tax Issues in FY 2016 Administration Budget Bloomberg BNA Summary of H R 5 1 Tax Increase Prevention Act of 2014 Client Letter on the Tax Increase Prevention Act of 2014 H R 5771 2015 Inflation Adjusted Items and Rates Bloomberg BNA Federal Tax Blog Special Report Net Investment Income Tax Issues Key GO Pages ACA Employer Responsibility BEPS Developments Capitalization Regulations s FATCA same Sex Marriage Summary Charts Tax Reform Tax Lien Purchasers Held Properties to Sell Had Ordinary Income Updated Limits on Auto Depreciation Deduction and Lessee Inclusion Amounts Announced Applicable Federal Interest Rates for February 2015 Interest Rates for Overpayments and Underpayments for Calendar Quarter Beginning January 1 2015 Bloomberg BNA Events h
39. ance s CASES Docket No 93 Civ 4483 LBS NEWS Decided Februarv 28 1996 s EXPERT ANALYSIS 79 AFTR2d Para 97 338 48 Federal Tax Cases 18 U S District Courts New York 18 303 West 42nd Street Enter Inc v IRS Case Citations Locate the Bloomberg BNA citation in the heading of the decision If a non Bloomberg BNA citation is available both the Bloomberg BNA and non Bloomberg BNA citations are listed in the title area This Case Cited In Choose a category to view where the current case is cited 303 West 42nd Street Enter Inc v IRS 4 Go to Hit P Results in U S Income 3 State Tax Portfolios 1 Sales amp Use Tax Portfolios 1 State Guides amp Navigators 2 News 54 Laws Regs Agency Docs 37 Cases 21 Search Options Edit Search Within Results Add to My Folders Clear Results for retail least Check to add to print selection list 303 West 42nd Street Enter Inc v IRS United States District Court for the Southern District of New York Docket No 93 Civ 4483 LBS z 48 Federal Tax Cases ili NEWS 18 U S District Courts New York 18 original pages EXPERT ANALYSIS 1B 1303 West 42nd Street Enter Inc v IRS S D N Y 199 Attorneys Judge CASES Cases and Decisions by date within court 21 documents gt Show esults by relevance Decided February 28 1996 Cite s 916 F Supp 349 96 1 USTC Para 50 189 Summary Opinion Text
40. ates Authors Advisory Board SEARCH My BNA O Bi AA A a Ste Sala o mt sates Aoeouesiea dTe Podica lpok lan Morel a Click PREFERENCES on the banner to Decide whether to use Search Suggestions Seta specific home page Select favorite collection s to display on the home page for one click access Decide how to view search results Search Suggestions On O off display screens SAVE CANCEL Click SAVE for each frame Set My Home Page The Tax and Accounting Center offers multiple My Home Page choices Below you can set a preferred My Home Page option that you will land on each time you open the Tax and Accounting Center You can return to your selected Tax and Accounting Center Home page when you click the My Home Page button in the banner User Preferences Jump to Set My Home Page Customize your Collections Search Results Display preferences Text Size preference After you have made your selections click the Save button Search Suggestions While typing terms in the search box in the upper right of the Tax and Accounting Center suggestions of popular searches are displayed based on the letters you have typed Selecting any of the suggested searches will fill the search box with the selected search The search may include additional terms such as applicable Internal Revenue Code sections synonyms and alternate phrasing If you prefer you may turn off the suggestions by selecting Off below
41. ates for the U S and Puerto Rico published during the previous 30 days on the New Rates tab Create an automatic or scheduled report of tax rate data using the Rates Exporter tab tt Votenow amp BBNA Editors QHelp Search New Rates Favorites Rates Exporter United States Canada Bloomberg BNA Sales amp Use Tax Rate Finder ZIP Code Introducing Bloomberg BNA s new Sales amp Use Tax Rate Finder designed for researching general sales and use tax rates With this new tool you have access to 9 digit ZIP code ZIP 4 and street address level sales and use tax rate information for taxing jurisdictions in the U S Puerto Rico and Canada Please note that certain special tax rates such as those applicable to food alcohol and accommodations as well as some district specific taxes such as ZIP those for airports are not presently supported To find your 9 digit ZIP code ZIP 4 start with the street address or visit the U S Postal Service USPS website Each address is automatically cleaned Clear standardized and verified using CASS software which is certified by the USPS to ensure it is correct and deliverable It is recommended to check with state revenue agencies to confirm tax rate information For more important information about the method used to identify tax rate information see the Frequently Asked Questions section of the Help menu above State County City To start your research 1 Click one of the menus ZIP Code
42. ch or saved chart click Saved Searches or Saved Charts Advanced Search Use the Advanced Search template to design a search within a specific collection Options for field searching and date limiters are also available on the template Guided Search Offers a variety of search forms designed to search within specific collections Specially targeted fields and search features are available for each type of collection Go To Use Go To to locate a document case or Expert Analysis with a full or partial citation Networking Links Follow Bloomberg BNA on Twitter and or Facebook Sign up for Email Updates See page 2 for detailed information on selecting Email Updates Authors List of 1 000 of the world s leading tax and financial accounting experts contributing to the Tax and Accounting Center Advisory Board Discuss taxation issues with our expert authors firsthand in an ongoing series of practitioner to practitioner monthly Advisory Board Meetings located in New York City Search My BNA Conduct a cross product search in all of your subscriptions by clicking Search My BNA Note this feature only appears if you subscribe to more than one Bloomberg BNA service ff MY HOMEPAGE SITEMAP PREFERENCES MYFOLDERS ACCOUNT PROFILE GETTING STARTED ABOUT CONTACTUS HELP SIGNOUT ext size SEARCH HISTORY SAVED SEARCHES SAVED CHARTS Bloomberg Tax and Accounting BNA Center All This Collection O This Portfolio ADVANCED S
43. clude only the filing requirements for the state taxing authorities as identified by you Accordingly our my services covered by this engagement letter do not include a determination of whether the corporation has filing requirements in taxing jurisdictions other than the one s of which you have informed us me If desired we I would be happy to provide you with a state nexus study to determine if the corporation has any other state filing requirements If this is the case please contact our my office to discuss the terms of and costs for such an engagement which would be memorialized in a separate engagement letter 30 Transactional Diagrams PRACTICE TOOLS Collection of tax diagrams designed to help visualize complex fact patterns and transactions in IRS guidance regulation examples Tables Charts and Lists and Bloomberg BNA products Access by I R C Section number or Quick Tax Reference browse or search using the Advanced Search template see page 11 to locate the relevant tranasctional diagram Tax Calculators Client Letters Elections amp Compliance Statements Transactional Diagrams Portfolio Working Papers FIND BY IRC SECTION Enter a Code Section below and click Tax Practice Series Aids Search Citation Examples Browse All Search All To browse click Browse All and menu walk through the subject areas Select the diagram you wish to view Transactional Diagrams amp
44. contained the following historical matter not on the former briefs Mr Attorney General and Mr Assistant Attorney General Whitney for the United States Opinion Text Total View All Direct History Summary Caution MR CHIEF JUSTICE FULLER delivered the opinion of the court 8 Negative Whenever this court is required to pass upon the validity of an act of Congress as tested by the fundamental law enacted by the Total people the duty imposed demands in its discharge the utmost deliberation and care and Invokes the deepest sense of responsibility And this is especially so when the question involves the exercise of a great governmental power and brings into consideration as Result s vitally affected by the decision that complex system of government so sagaciously framed to secure and perpetuate an indestructible judgment Reversed Case Union composed of indestructible States Remanded Order Vacated We have therefore with an anxious desire to omit nothing which might in any degree tend to elucidate the questions submitted and aided by further able arguments embodying the fruits of elaborate research carefully re xamined these cases with the result that while our former conclusions remain unchanged their scope must be enlarged by the acceptance of their logical consequences Description of BCite Indicators Citing Case Analysis Click the Citing Case Analysis tab to see how many times the case has been cited pos
45. cumentation requirements for a foreign recipient to be eligible for it b A percentage of dividends from a U S corporation that continuously from years before January 1 2011 earned at least 80 of its income from an active business conducted outside the United States and c Dividends received by a foreign government acting in a non commercial capacity 30 in general Significant exceptions however may often be more important than the general rule 0 in the case of a Interest on deposits in banks and savings institutions or under certain arrangements with insurance companies b Portfolio interest interest on debt issued under procedures that provide identification of the holder which covers virtually all public and government debt as well as much private debt but requires that the debt is not i held by a bank making a loan as part of its business nor ii held by a 10 direct or indirect shareholder of a corporate obligor nor iii contingent on income value or similar economic factors c Interest on short term obligations 183 days or fewer from original issue d Interest on obligations issued by states or their political subdivisions and e Interest received by a foreign government acting in a non commercial capacity and interest on deposits and certain obligations of the U S government and its agencies and instrumentalities received by a foreign central bank of issue likewise acting in a non commercial capacity
46. dates GETING STARTED 86 ABT Authors Advisory Beard Set az My Home Pag Search this tab GO TO DOCUMENT BY CITATION Internal Revenue Code 4 JEN EXPERT ANALYSIS List of Portfolios Chapters Citation Formats Options x Fast Answers Federal Tax U S Income Portfolios Indexes Keyrord IRC J u Income Tax Accounting Corporations Compensation Planning Carpewate Returns and Computation af Tax s Income Deductions Credits and Computation of Tax Matural Res iree s Other Pass through Entitles s Procedure and Administration Partnerships Real Estate Estates Gifts and Trusts Portfolios Indexes Keyword IRC U S International Portfolios index Tax Practice Series l Indexess Keyword IEC U S Tax Overview Navigators Federal Excise Tax a Green Incentives Advisers s Health Care Relorm u IRS Practice Indexes Keyword IAC Taxation of Exchange Traded Options Books amp Treatises PLI Treatises Getting the Dal Through Section 4004 Handbook Search Expert Analysis r FAVORITE COLLECTIONS Customize this area with your choice of links ta the Tax and Accounting Center s collections Go to preferences H See all collections H CONTACT US HELP SEARCHHETOAY DIVEN BEACHES FAVED CHARTE ADVABCED SEACH UDEBSEMEH GTO RADAR A SIGN OUT axl sig SEARCH My BHA D Federal i Daly Tax Compensation amp
47. e Returns and Computation of Tax U S Income Portfolios Corporate Returns and Computation of Tax Working Papers U S Income Portfolios Income Deductions Credits and Computation of Tax U S Income Portfolios Income Deductions Credits and Computation of Tax Working Papers U S Income Portfolios Natural Resources Working Papers U S Income Portfolios Other Pass through Entities U S Income Portfolios Other Pass through Entities Working Papers U S Income Portfolios Procedure and Administration U S Income Portfolios Procedure and Administration Working Papers U S Income Portfolios Partnerships U S Income Portfolios Partnerships Working Papers U S Income Portfolios Real Estate U S Income Portfolios Real Estate Working Papers move up B move down Expert Analysis Search Results Display Order Expert Analysis by Portfolio Chapter Number O Order Expert Analysis by Relevance Cases Search Results Display Order Cases by Date within Court O Order Cases by Relevance Index Search Results Display If you want to see only your Index search results without the rest of the Index select View hits only If you want to see your Index search results highlighted in context within the entire Index select View hits in full index View hits only O View hits in full index cance The Tax and Accounting Center provides intuitive and comprehensive access to Bloomberg BNASs full collection of tax and account
48. e client ready reports that compare company Evaluate multiple years activities to what the states reported as nexus creating contracts on the annual Bloomberg BNA Survey Get quick answers of State Tax Departments Create and archive reports s Create and save charts You can choose between Corporate Income Tax Nexus Sales amp Use Tax Nexus and Trust Nexus plus use our Chart Builder feature to see how the state answered nexus related questions Tarea Tour EVERYDAY TAX AND ACCOUNTING CENTER FREE EXCEPTIONAL iiio te mosi compie Because being exceptional is staying one sop ahead of your Conky chalenges every day TAX FORMS All Bloomberg BNA Interactive Tax Forms are government approved Automated form processing requirements for barcodes scanlines validation fields etc are built in to guarantee filing requirements are met New and updated forms are added to the collection as they are released by the issuing agencies To access Tax Forms on the Web click Tax Forms Interactive in the Tax Forms frame on the home page TAX FORMS amp GUIDES feral Tax DD Tax Prep Guides offer comprehensive how to guidance for preparing forms 706 709 940 941 1040 1047 1065 1120 and 1120S Tax Prep Guides 2014 Tax Prep Guides Archive The Federal Tax Guide covers taxation of individuals corporations estates and trusts and pass through entities It includes a special Choice of Entity section and provides businesses w
49. e the Evaluator and identifv the Company Follow the numbered steps and make selections for Year Jurisdictions and Categories For a description of each Category listed in A click the Details icon EJ Click Complete Setup State Income Tax Sourcing Evaluator New Evaluator Denotes requred field State Income Tax Sourcing To lHome tep w Sign Out New Chart Saved Projects ia Name Your Evaluator ED Select A Year Evaluator Year E Select Your Jurisdictions Add at least one jurisdiction to your project Select AN Deselect Ail LI Alabama LI Alaska O Arizona O Arkansas UI California LI Colorado CO Connecticut U Detaware LI District of Columbia LI Florida O Georgia U Hawaii LI Idaho LI Illinois EA Select Vour Categories LI Receipts from Real Property CI Receipts from Services General LI Receipts from Intangibles U Indiana U lowa O Kansas C Kentucky U Louisiana LI Maine C Maryland L Massachusetts O Michigan LI Minnesota C Mississippi U Missouri L Montana LI Nebraska Add at least one activity category to your project Select AV Deselect All C Receipts from Sales of Tangible Personal Property L Receipts from Leases Licenses or Rentals of Tangible Personal Property C Nevada CI New Hampshire C New Jersey C New Mexico C New York CI New York City C North Carolina U North Dakota U Ohio CO Oklahoma CO Oregon C Pennsylvani
50. eld Properties to Sell Had Ordinary Income Updated Limits on Auto Depreciation Deduction and Lessee Inclusion Amounts Anmounced ua Applicable Federal Interest Rates for February 2015 a Interest Rates for Overpayments and Underpayments far Calendar Quarter Beginning January i 2015 u Blownberg BNA Events http ww bnatax Dnmitaxeventa RECENTLY VISITED DOCUMENTS Foreign Account Tax Complianca Act FATCA SUBSCRIBER FEEDBACK INDEXES Bloomberg BNA Indexes are compiled bv legal subject specialists Click the Indexes button to displav the linked list of indexes Some content collections have an index link next to the name link 1 The topic specific Indexes Finding Aids window displays 2 To browse click an index link and menu walk through the content Click the citation links to view full text 3 To search use the Advanced Search template and select any or all of the specific indexes for the search 4 Some indexes are also accessed by a link next to the content Indexes amp Finding Aids Federal Tax Expert Analysis Indexes Estates Gifts and Trusts Portfolios Index Tax Practice Series Index IRS Practice Adviser Index IRC Coverage in Portfolios Index IRC Coverage in Tax Practice Series Index IRC Coverage in IRS Practice Adviser Index News amp Commentary Indexes Daily Tax Report Index Tax Core Index Weekly Report Index Tax Management Memorandum Index Compensation Planning Journal Index Es
51. elevent treaty article number is indicated with explanatory text setting out the circumstances in which a given rate applies Mote that in some circumstances the source country s domestic law rate may apply rather than the treaty rate most obviously because the treaty rate exceeds the domestic law rate Anote ill indicate if the Domestic Rates tab must be consulted to identify the applicable rate The income streams identified in the chart are L Strategie Dividends inter corporate dividends to an investor company holding some minimum specified level of participation in the dividend paying company 2 Portfolio Dividends any dividends not falling inta the category of strategic dividends If the treaty does not distinguish between strategic and portfolio dividends this is indicated 3 Specific Kinds of Interest particular types of interest that may be singled out by a treaty for special treatment typically exemption from source country tax If no kinds of interest are given special treatment this is indicated 4 Interest Generally interest not falling inta the category of specific kinds of Interest Royalties if the treaty provides more than one rate for royalties typically based on the nature of the right or property giving rise to _ 2 the royalties the chart shows the kinds of royalties to which each rate applies The chart makes a number of general assumptions most importantly 1 that the income recipient is a residen
52. es Gifts and Trusts gt Estate and Gift Taxes gt Net Investment Income Tax Application to Estates and Trusts Previous Next 16 lt GO gt Page istemamj Net Investment Income Tax Application to Estates and Trusts For tax years beginning after December 31 2012 in addition to any other applicable taxes estates and trusts must pay a 3 8 tax on the lesser of 1 the undistributed net investment income for the tax year or 2 the excess if any of a the 67 e adjusted gross income for the tax year over b the dollar amount at which the highest tax bracket under 1 e for estates and trusts begins 852 T M IV C pplication hreshold Amounts The threshold amount is the dollar amount at which the highest tax bracket applicable to estates and trusts under 1 e begins for the relevant tax year In 2014 the threshold amount for an estate or trust is 12 150 852 T M IV C 5 Reporting An estate s or trust s net investment income is determined and reported on IRS Form 8960 which is to be attached to and filed with IRS Form 1041 852 T M IV C 5 gt Computation gt Practice Tip gt International Considerations Related Topics Net Investment Income Tax Application to Estates and Trusts For tax years beginning after December 31 2012 in addition to any other applicable taxes estates and trusts must pay a 3 8 tax on the lesser of 1 the undistributed net investment income for the tax year
53. es and Built In Gains Document Type IRC Section IRS Announcement 2015 8 on Supreme Court Ruling on Claims for Employment Tax Refunds IRS Notice 2015 11 on Qualified Zone Academy Bond Allocations for 2014 FAMA IRS Notice of Individuals Who Chose to Expatriate for Quarter Ending Dec 31 2014 Finding Tools Internet Tax Freedom Forever Act bv Sen Thune Index Archives Search Indexes Browse Indexes c Sign up for email updates Bloombe A Bloomberg BNA rg TaxCore BNA TaxCore LATEST NEWS RECENT TOPICS Sign up for email updates Document Type E close Llevel close all amp LATEST NEWS RECENT TOPICS FINDING TOOLS FINDING TOOLS amp open 1 level open all open i level openall Bl dloseilevel close all Split Screen TaxCore Document Tvpe 8 Congressional Documents Correspondence Congressional Documents Legislation Congressional Documents Legislative Summaries Congressional Documents Miscellaneous Congressional Documents Reports Congressional Documents Statements Court Documents Federal Courts Court Documents Miscellaneous Court Documents State Courts Court Documents U S Supreme Court Court Documents U S Tax Court International Documents Miscellaneous International Documents Tax Forms International Documents Tax Treaties Next TaxCore IRC Section a Section 1 B Section 01A 03 25 2013 CCA 201312032 Section 01A 02 01 2010 CCA 201004026 Section 1A Section 2 Section 03 BBBB
54. f each donor s gift is the aliquot purtieri of tha DISCS asset value at the date of transfer A B ard hawe made and will Ooritiiie bo make gits Of profits that would otherwise Mow to H in the absence of the agreement with the DISC These gifts occur each time M sells its products by way of the DISC The gifts continue as long as the agreement is in effect The total value of the gifts by each donor ts one third af the am unt transferred to the DISC on each sale Bloomberg Transfer Of DISC Ta Trusis dnd Continued Cantractual Relationships Are Taxable Gifts SOURCE Am Ful fil 51 1961 4 CB 476 REFEREMCE LRC 2801 25Hbr Reg Gh 2561 1 SRR 25281 1 He SUMMARY Gorani Ms a donmesi marui Guiness cmanined in 1972 whith see one hall of fu erducts cutee fhe Lined Biais Al fhe dock of M is ganed in equal shares by individuals A E aed C in Jarry 1976 in onder ta mame than proli abiitv of erp business of MLA B ara C immed a DSC Emh them tansientid 31 000 in cash ia tha DSC in eochange ior equal shares of DSE Immediieti tamae A B and C made oie of all of ther DEC stock ta tees imeen hum ceased forthe benefit of thet murarier mino ices Each of the senses of A Bando wee designated as sok uit of the Tues for fer epore biren The mues of the fires rusts wan g an tall power ta deal wiih fhe Tu assets 28 E hery owned foes assets aright ARa the DISC stock was lransterred bo g of bl with marat a Ms bmsinezz tur which Be DEC is io be pj I
55. fore the deadline Rosenberg said splitter transactions Changes Takeaway The rules litte changed from The final rules include some changes to the rules addressing splitter arrangements involving reverse hybrids loss sharing previously proposed and hybrid instruments rules are seen 25 A Harrington said new examples for reverse hybrids and hybrid instruments are helpful if only to illustrate the technical balanced way to rules and definitions He sald changes In the final rules are not always taxpayer favorable Implement the law However he said the changes do clear Up questions such as how to taka into account loss carryovers and whether taxpayers should use foreign law or U S law in determining whether a hybrid splitter arrangement exists Harrington said the IRS hasn t yet changed interim rules for identifying related income and split taxes and said more specific guidance is needed The agency sald in the preamble to the final regulations that It is continuing te work om such guidance Harrington told Bloomberg BNA that even though the final regulations apply only to defined situations taxpayers and practitioners need to keep them in mind when undertaking cross border transactions and planning Bigger Picture For example he said if a foreign subsidiary has discretion whether to carry back a loss it needs to take Into account whether falling ta carry back that loss could subject its group to the regulations
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57. he field then click Add to Search Show fields from all selected Limit by date e OFrom To Ex mm dd yyyy Ex mm dd yyyy jae GGG Reset Form EAA Search Operators Use operators to show relationships between search terms Click on an operator to add it to your search 21 SOURCE DOCUMENTS Laws amp Regulations Each tab has a Source Documents frame with the selection of primarv source l l u Internal Revenue Code Current Index documents pertinent to the subject area of each tab Internal Revenue Code Archive a Treasury Regulations Index To go to a document by citation see the home page or click the Proposed Treasury Regulations Go To link on the banner see page 13 i Agency Documents a Treasury Decision Preambles To browse click the link to the appropriate document and menu walk through the file a IRS Documents IRS Publications u Circular 230 To search use the Advanced Search template and use the option to CIPs ISP Papers search in specific files using fields and date limiters e MSSP Audit Guidelines Cases Source Documents could display with buttons linking to Federal Tax Cases All Bloomberg BNA Analysis and News i Soe 7 Code History a Court of Federal Claims Rules Committee Reports Fast Answers Key Bloomberg BNA Analysis New Law Analysis a listing of most relevant content News amp Commentary Portfolios and u Treasury Regu
58. i cannes A B ari E mich ids bata iti eel s an i fer BIS t tea nai ee Hob tard pe aiaa Ta sabi of kel danai i gi is a UE pabo dil Ba CS dice ide ih date ol kanika A Bar arse ric ai el DEL le rota gis sl piai al would silkratu New tod i Fi aiara ol Ba agan wih ee DS Teac DEELT aah limna Mi Sells ih product by wiri of he DSC The Conte a jon d a aea b B bieri Tha total aha of the by eect dona bi tmi Rird al the adul Bambi ti the DESC on each aiia DH Uno ii an A d d Cee ei B i poe H A B ard Tmur eee as train hanier Tran lin ie bed ni resperir hee E Eri Tik MARGRET HEL g taiii H The Bi d ana itiru i Aig A PRACTICE TOOLS STATE a Portfolio Working Papers There are state specific Practice Tools Click the State tab locate the Practice _ iia Pilea tia Tools frame and select from Working Papers Client Letters Sales and Use Tax Rate Finder State Tax Chart Builders State Income Tax Sourcing Tool and State Tax Nexus Tools for Corporate Income Tax Nexus Sales and Use State Tax Chart Builders Tax Nexus and Trust Nexus 50 State Overview a I R C Conformity Corporate Income Individual Income Sales and Use u Excise a Property Estates Gifts and Trusts State Income Tax Sourcing Tool State Tax Nexus Tools a Corporate Income Tax Nexus Sales and Use Tax Rate Finder Sales and Use Tax Nexus Find tax rates for the U S selected territories and Canada on the Search tab s Trust Nexus View all tax r
59. ia H Colorado Connecticut Delaware LI District of Columbia x go Florida 2014 2014 Save My Search Open Saved Documents Profiles Ctrl O Description Specifications for Filing Wage and Tax Infor Corporation Income Tax Return Instructions to Form 20C Schedule AB Add Back Form Instructions to Schedule AB Consolidated Corporate Income Tax Return Instructions to Form 20C C Election to File Consolidated Corporate Inco Corporation Information Tax Return Instructions to Form 20S Schedule NRA S Corporation Nonresident A Instructions to Schedule NRA Individual Income Tax Return Residents and Instructions and Worksheets to Form 40 Individual Income Tax Return Full Year Resi Instructions and Worksheets to Form 40A 37 38 Forms Workspace Filing information automatically displays when a form is opened Fields are color coded Red Required field Aqua Fill in field Green Auto calculate field A Yellow outline indicates the active field Right click in any line to display the Line Instructions To display the Tax Tables and Rate Schedules right click anywhere in the Line Instructions Note not all forms have line instructions J Interactive Forms Fie Edt View Documert Window Help DeL AHX naL m QBOB XIJJE FORM B 40 Alabama 2014 Individual Income Tax Return RESIDENTS PART YEAR RESIDENTS For the year Jan 1 Dec 31 2014 or other tax year Ending
60. il for Daily Tax Report l l If vou haven t selected email vet and want to do so now go to the email sign up page To view the subtopics included in each topic click the Info icon e can be reached from links on vour Dailv Tax Report home page Check a box to make a selection Click the info icon for more information If vou make more than one selection articles on anv of these will be placed at the top of vour customized email and links for each selection will appear on vour home page To delete a selection click the X Customize by Your custom selections w Topics v charitable contributions deduction corporate income tax e credits and incentives employee benefits environment Topic hierarchy estate tax tax executive compensation income ii income tax exempt organizations corporate income tax federal budget type of tax federal tax legislation business tax gift tax l corporate income tax TP income tax individual income tax corporate income tax investment income Topics corporate income taxid x Topic corporate income tax OOOOOOOOOOORLD Preferences MYHOMEPAGE SITEMAP PREFERENCES MYFOLDERS ACCOUNT PROFILE GETTING STARTED ABOUT CONTACTUS HELP SIGNOUT Textsize a WAOA Tax and Accounting SEARCH HISTORY SAVED SEARCHES SAVED CHARTS Use Preferences to customize the Boomberg Tax and Accounting Center N Follow us on Twitter BiFacebook amp Sign up for email upd
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62. ing statutes regulations analysis case law domestic and international news and practice tools The platform covers all areas of tax and accounting law additionally filtered into topic areas such as Federal Compensation amp Benefits Estate Planning State Sales amp Use International Transfer Pricing Accounting Tax Practice Payroll and these additional practice areas Accounting for Income Taxes Green Incentives Real Estate and Tax Exempt Organizations Bloomberg BNA s content is created by the legal publishing industry s largest and most experienced editorial staff Our legal editors are subject matter experts not generalists The legal editors of Bloomberg BNA s Tax and Accounting Center review all tax and accounting cases then draw upon decades of experience to Carefully identify the significant points that every tax and accounting practitioner needs to see The editors also analyze and pull together the relevant laws and regulations The Tax and Accounting Center makes research fast easy and accurate with expertly prepared indexes It offers an intuitive search interface with advanced search capabilities and simple easy to use navigation Some of the content included in the Jax and Accounting Center BNA Insights articles featuring expert analysis from leading practitioners on key developments and trends in tax and accounting practice Fast Answers Federal and State Jax Na
63. ith options available to help determine which form of business entity is the most appropriate for a new or restructured enterprise Federal Tax Guide Federal Tax Calendar Toolbar Click the toolbar buttons for the primary functions in the forms Hover over a button to display the button s function Click the User Manual button 9 for in depth information about using Interactive Forms Click Help then select Tutorials for additional assistance with Interactive Forms New Documents Click the New Documents B button Select a Tax Year from 2001 current vear forms are available Select a Jurisdiction Federal or States IRS Publications Practice Aids or Quick Guides amp Directories The available form s displav in the right column Select Form Number s or document s title as pertinent Click Open Saved Documents To access previously saved Documents and Profiles click the Open Saved Documents Profiles cy button Edit View Document Window Help X B m BOl 4 Le File Edit View Document Window Help x User Manual Screen Calculator About 11178 Found From 1 Jurisdiction Finished Select a tax year and one or more jurisdictions Filter Results By Tax Year Form Number or Key Word Current Year Forms Internet User Manual F1 C Federal CI IRS Publications C Practice Aids DI Quick Guides amp Directories A B States Alabama C Arizona L Arkansas C Californ
64. itively or negatively distinguished and whether or not it has been superseded by statute Citing Case Analysis shows a cited case and extracts showing the exact language used by the citing court The chart can be filtered by Date Court or Analysis Click a case name to display the full text as it displays in Bloomberg Law The case will not be linked To view a linked case copy the case citation and use the Go To template in the Tax and Accounting Center Click a category e g Distinguished Caution etc to view the list of cases Direct History Click the Direct History tab to trace the history of a case through the court system Direct History lists the cases related to the main opinion and displays links for cases that are affected by the outcome of subsequent cases Table of Authorities Click the Table of Authorities tab to view a list of the cases cited within the case An icon specifies the composite treatment for each case Sort by Case Name Date Court and or Analysis Direct History Citing Case Analysis Table of Authorities Table of Authorities J Pollock v Farmers Loan amp Trust Co 158 U S 601 15 S Ct 912 39 L Ed 1108 1895 Select a radio button to filter the results as Table of Authorities O G Positive Analvsis Court Name Case Name O Distinguished Supreme Court of the United States b 1 Superseded Statute Natl Fed n of Indep Bus v Sebelius 132 S Ct 2566 183 L Ed 2d 450 53
65. ject C Usersiah5 6 Desktop MyCurrentEvaluator Browse Y Scannin g for Viruses Success Accepts xls xlsx file types w Checking Export ID Success w Matching Project Criteria Success w Verifying Question Format Success Success Your project has been validated successfully PLEASE NOTE By clicking Complete Import you will be overwriting your existing answers with your imported answers Cancel Complete Import 35 State Income Tax Sourcing Evaluator continued The linked Report downloads 2014 California Income Tax Sourcing Report as a MS Word document and March 18 20154 and can be printed or saved This report is an analysis of business income apportioned to the state based on a comparison of business income received from certain activities to the state s positionon how income received from those activities is sourced between states State positions are derived from an annual survev conducted by Bloomberg BNA in which states are asked whether they follow certain in ome sourcing methods and from an analvsis of relevant law The source of each determination is indicated in the footnotes 5 1 The followins lists the receipts from certain activities which will be considered sales in the state as well as the receipts from certain activities which will not Activities which mav or mav not be considered as receipts from sales in the state are also listed Furthermore sourcing determination
66. lations ERISA Health Care amp Labor Source Material Excise Tax Source Material Search Source Documents Advanced Search Select collections to search from the categories below then use the search form to perform your search choose collection s to search Select one or more of the following optional crite Expand All Collapse All Select All Clear Selected Collections your search L JEXPERT ANALYSIS o n L I NEWS AND COMMENTARY Search term s w WI LAWS REGULATIONS AGENCY DOCUMENTS Ea Reset Form ZITAX V EXCISE TAX i TAX ARCHIVES b p gt WITAX ARCHIVES BY STATE b iv ACCOUNTING STANDARDS AND REGULATIONS o Fields V LABOR amp EMPLOYMENT HEALTH CARE COMPLIANCE Show shared fields only O Show fields from all selected collec CASES AND DECISIONS L IPRACTICE TOOLS TAX FORMS Choose a field enter search terms for the field then click Add to Sea INDEXES AND FINDING AIDS EVENTS amp TRAINING STATES Limit by date No Date Restrictions V O From e To Ex mm dd yyyy Ex n Ez Reset Form Internal Revenue Code Current Buttons Hide E open i level open all E close 1 level close all e Full Screen E Full Screen Previous Next Check to add to print selection list amp G Regs Code History Committee Reports New Law All BNA Key BNA Portfolios Fast Answers News Internal Revenue Code Current Subtitle A INCOME TAXES Sections 1 to 1564
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68. lectricity Production Credit 4 Qualified b Wind Facility PRINT DISPLAY Print or Display your selections CI Select All Deselect All List of Document s 1 Tanner Gordon et ux et al v Commissioner T C 1992 Federal lax Cases gt U S Tax Court 2 M Unpublished Sky River LLC v Kern County Cal Ct App 2013 gt a l N EEE TAN ES lifarmi State Tax Lower Court Cases gt California Remove Checked Documents From List Tax and Accounting Center Bloombe BNA 3 Source Federal Tax Cases gt U S Tax Court gt Tanner Gordon et ux et al v Commissioner l Tanner Gordon et ux et al v Commissioner United States Tax Court 39 COMPLIMENTARV BLOOMBERG BNA TRAINING Visit www bna com training or call 800 372 1033 Express Training Designed for the busv professional this session gets you up and running in 30 minutes or less Express training familiarizes you with the basic functions of the product and shows you how to access a wide range of content and practice tools Basic Training This hour long course prepares participants to conduct basic research by using the content of the Resource Center to retrieve information quickly and efficiently Participants will also experience the integration of the Resource Center s components expert analysis news and developments primary sources special reports and practice tools Employing three different research strate
69. lose Llevell close all Split Client Development Letters Go Browse Contents Check to add to print selection list eae ea ere lient Development Letters gt Tax Accounting gt Permissible Accounting Methods Peres Ret Client Development Letters kmgletotika Dear i E Gross Income l l l l NA l Whether you re looking to select an accounting method for a new business or reviewing your options for an Ded uctions existing business the accounting method you choose to report your income and expenses affects more than just E R o your tax return Credits Computations and AMT In fact the term accounting method not only includes the overall method of accounting you use it also includes g Tax Accou ntinc the accounting treatment vou use for anv item z z But if you don t regularly use an accounting method that clearly reflects your income the IRS will determine your LI Permissible Accounting Methods income for you using a method of its choosing Why put your business your work your passion your time in the O hands of the IRS Valuation of Inventories Together we can examine the accounting methods available and choose one that s specifically suited for your s business Your accounting method must treat all items of gross income in a consistent manner from year to year Tax Practice and Procedure and it must show the consistent use of generally accepted accounting principles for your trade or business Which H method you use however
70. ly Tax Report News Archive gt 2015 gt February gt 02 10 2015 gt Federal Tax amp Accounting gt Tax Credits Protease Went Foreign Credit Splitter Rules Praised As Reasonable Approach to Section 909 b See MHH Aries A Coris Editor L aprizin B P errmanzionii Tax Credits r 27 DTR G 6 Foreign Credit Splitter Rules Praised As Reasonable Approach to Section 909 a By Alison Bennett Feb 9 New final IRS rules on foreign tax credit splitter transactions won praise from practitioners as a reasonable approach to implementing tax code Section 505 designed to curb such splitters Issued Feb 5 the rules T D a7 10 RIN 1545 BK 50 keep the exclusive list of splitter arrangements in the temporary regulations the IRS put for ee pears ago with some changes 27 DTR G 10 2 10 12 Censidering the breadth of Section 909 as enacted this exclusive list approach is a reasonable balance behind Section BNA Snapshot 09 and the need for administrable rules John Harrington a partner at Dentons LLP told Bloomberg BNA Feb Development Final IRS rules to implement tax code Section 905 curb foreign tax credit Both Harrington and Rebecca Rosenberg a tax principal in the Washington National Tax Services practice at PriceweterhouseCoopers LLP praised the timing of the rules issued on the same day the temporary rules expired Practitioners were waiting with bated breath to see if final regs would be issued be
71. na com To contact the editor responsible for this story Brett Ferguson at bfergusonifibna com For More Information Text of T D 5710 is in TaxCora Related Articles Topics u ililiated groups federal tax a f il Tax Core Access the full text of thousands of congressional tax bills IRS regulations and guidance court decisions official reports statements transcripts memoranda rulings opinions and other materials issued by public and private sector agencies and organizations with TaxCore View documents by Document Type or IRC Section To search use Advanced Search and search in the Jax Core Indexes LATEST NEWS IRC Section Check to add to print selection list ACCOUNT PROFILE CONTACTUS HELP SIGNOUT Text size OA AOA JEDD Advanced Search Search History Saved Searches HOME CUSTOMIZETOPICS MY FOLDERS Bloomberg A B N A TaxCore GETTING STARTED ABOUT RECENT TOPICS bd Sign up for email updates FINDING TOOLS SEARCH My BNA Welcome BBNA Editors Recent Topics All Headlines Print Now Customize 4 Issue dated Wednesday February 11 2015 e Number 28 All Recent Topics gt 2014 Instructions for Form 1120 REIT U S Income Tax Return for Real Estate Investment Trusts View Documents 2014 Instructions for Form 1120 RIC U S Income Tax Return for Regulated Investment Companies By 2014 Instructions for Schedule D Form 1120S Capital Gains and Loss
72. natory Letters Gross Income Deductions Credits Computations and AMT Tax Accounting Tax Practice and Procedure Partnerships S Corporations C Corporations Compensation Planning Income Estates and Gift Taxation Exempt i ial and Private Foundations Foreian 11 100 4 etter Application of U odel Tax Treaty to Dividends and Royalties C147170 100 Client Letter Withholding Obligations Npon Sale of Real Property by Foreign Person 197170 200 Client Letter Foreign Account Tax Compliance Act 3 Client Engagement Letters Check to add to print selection list Client Engagement Letters Client Explanatorv Letters Go Browse Contents References Show Eh m Q ch fal emit Canann News 8 Commentarv Client Explanatory Letters gt Foreign Taxation gt 47150 100 Client Letter Exclusions Previous Hex for Citizens and Residents Employed Abroad This letter is to remind you of our upcoming meeting and to give you some background information so that we may discuss your tax situation more constructively when we meet You told me that you are an airline pilot for a U S airline and that you earned income from flying abroad You reside overseas You are inquiring as to whether you may exclude for U S tax purposes any of the income you earned while working abroad throughout the year You also wonder whether you may exclude other expenses that you incurred or that were paid on your behalf by your employer while flying
73. nd Accounting SEARCH HISTORY SAVED SEARCHES SAVED CHARTS BNA Center pei investment income tax OR HIIT ADVANCED SEARCH GI DED SEARCH GOTO Follow us on Linkedin U Twitter Wi Facebook El Sign up for email updates Authors Advisory Board E Federal b desl Tax Compensation amp Estate State Sales b International ines Accounting u Practice Payrol More All Benefits Hanning Use Series Practice Areas l Search Results Search Options Add to My Folders Results for net investment income tax OR NIIT Your search returned 681 documents Click on categories below to view search results 7 lt GO gt Pages r back aewers Net Investment Income Tax 45 5 Income Portfolios 0 Federal Excise Tax Navigator In addition to all other taxes individuals estates and trusts 13 Federal Advisers must pay a 3 8 tax on net investment income if their 9B oaks a Treati ises modified gross income exceeds the threshold amount More Kev BNA Portfolios 0 Tax Treaties Analysis 1 International Navigators amp Guides Income Tax Liability Concepts and Calculation 507 T M 5 Countries ILE l toll Key Code and Regulation Sections 0 Sales amp Use Tax Portfolios ILE C 1411 0 State Guides and Navigators Reg 1 1411 1 1 1411 10 7 States Related Analysis Unearned Income Medicare Contribution Tax Net Investment Income Tax 852 T M IV C 5 Net Investment Income Tax TPS 93310
74. or 2 the excess if any of a the 67 e adjusted gross income for the tax year over b the dollar amount at which the highest tax bracket under 1 e for estates and trusts begins More Key BNA Portfolios Income Tax Liability Concepts and Calculation 507 T M IE Income Taxation of Trusts and Estates 852 T M IV C 5 Kev Code and Regulation Sections I R C 1411 a 2 Reg 81 1411 3 Fast Answers What are some examples of items that are included in net investment income What are some examples of items that are not included in net investment income What is net investment income Practice Tools Client Letter Proposed Letter Concerning Net Investment Income Tax Client Letter 3 8 Medicare Tax on Net Investment Income Complex Trust Case Study with Filled In Form 1041 Form 8582 and Form 8960 IRS Form 8960 Net Investment Income Tax Individuals Estates and Trusts Related lt GO gt Pages Net Investment Income Tax Passive Activity Trusts Previous Next BCITE ANALVSIS The BCites Analysis frame displays on selected case pages Use BCitesM to validate whether a federal or state case is stil follow a case through the court system and locate cases in higher courts and or with similar facts or law at issue good law To view the list of cases cited within an opinion see the Table of Authorities Click any of the icon indicators to display the detailed tabbed dis
75. orm construction and paid the genera 18 Detailed Analvsis 1911 45 d 1 as amended 18 II Substance and Form 1912 18 Mb 3 Sham Transaction Doctrine is Bl 1 Foundation Rice s Toyota World 2 Rise of the Unitary Sham Test B 3 Implications of Unitary Test 1913 PLR 9417040 B 4 Sham by Association Defeasance Transactions 5 Time Value of Money 6 IRS Profit Guidelines 7 Sham Transaction Doctrine Justification Bibliography ar leans A U S Income Portfolios by portfolio 3 documents esults bv relevance gt Show 28 U S Income Portfolios Income Deductions Credits and Computation of Tax 1213 Iq For a discussion of d 1214 id The IRS has ruled that wind turbi tests for the various components generating unit is synchronized i turbines are placed in control of ti electricity notwithstanding the fa available for use and producing c towers and their supporting pad Tax and Accounting Center Bloombe BNA 3 Select a text format Printer friendly version for full screen viewing and printing from the browser O Rich Text Format RTF for importing into a word processing program e g MS Word PRINT DISPLAY rink Diepiny Do ifolio P CANCEL Select Portfolio segment s to Print Save O Portfolio 512 1ist Tax Incentives for Production and Conservation of Energy and Natural Resources Detailed Analysis III Production Incentives in the Form of Credits E Renewable E
76. ou wish to display isdicti oose Jurisdictions elect Topic s to Display Choose the Jurisdictions Ch Jurisdict Select Topic s to Displ Expand All Collapse All Select All Items Clear All Items Expand All Collapse All Select All Items Clear All Items Select a Topic s v States and Territories X Tax Imposition Jurisdiction and Interstate Issues Alabama Imposition of Tax Alaska w Nexus Select a Chart Display vesinik bnan Arkansas Credit for Tax Paid in Another Jurisdiction California L Interstate Agreements Click Create Cha rt v Colorado Streamlined Sales Tax Membership Connecticut 4 Definitions Delaware x Tax Rates j District of Columbia 2014 State Sales and Use Tax Rates Florida L 2013 State Sales and Use Tax Rates Georgia 2012 State Sales and Use Tax Rates Hawaii 2011 State Sales and Use Tax Rates Idaho 11 2010 State Sales and Use Tax Rates Illinois 2009 State Sales and Use Tax Rates Indiana Local Sales and Use Tax Rates Iowa gt Tax Base Kansas b Taxation of Property Kentucky Louisiana Taxation of Services 5 Exempt Entities Maine Exempt Transactions Maryland Exempt Intended Uses Massachusetts Special Situations Michigan a Administration and Procedure Minnesota MAR mate Local Taxes Mississippi Missouri Montana Select Chart Display Nebraska OTopic headings across top e Nevada Jurisdictions across top New Hampshire New Jersey Create Chart Reset New Mexico
77. play of Citing Case Analysis Direct History and Table of Authorities Toggle On Off POLLOCK v FARMERS LOAN amp TRUST CO l N L Go Browse Contents Search Options Edit Add to My Folders Clear N Go to Hit P Click Hide BCite Analysis B to toggle S BCitesm on off on 9 Add to My Folder Share tim Splt Screen Results for CASENAME Pollock AND v AND Farmers Federal Tax Cases gt U S Supreme Court gt POLLOCK v FARMERS LOAN amp TRUST CO U S 1895 v FARMERS LOAN amp TRUST CO United States Supreme Court Nos 893 894 Decided May 20 1895 Argued May 6 7 8 1895 BCitesv Indicators Click Description of BCite Indicators located at the bottom of the frame to view the definition list for the Pollock citator s indicators E Farmers Loan and Trust Company Rehearing Hyde Composite Analysis Superseded Citing Case Analysis Summary Positive Distinguished V Continental Trust Company Rehearing Composite Analysis Summary Displays the overall analysis of the case O Caution Case History and Disposition APPEAL FROM THE CIRCUIT COURT OF THE UNITED STATES FOR THE SOUTHERN DISTRICT OF NEW YORK Attorneys Mr William D Guthrie and Mr Joseph H Choate for appellants Mr Clarence A Seward Mr Benjamin H Bristow Mr David Willcox Q Superseded by Statute Negative Hide BCite Analysis lii Mr Victor Morawetz and Mr Charles Steele were on their brief which
78. r current States settings Update Schedule Exports Each zip file contains a CSV file Click to download the zip file Then open the CSV file in Excel en ose ere ti Testing CO PA 05 15 2015 09 07 46 5807 zip Export Now Export immediatelv with the settings below Jurisdiction O Use scheduled settings e States Edit your states list Your currently selected states are PENNSYLVANIA Favorites See favorites You currently have 2 favorite jurisdictions Note Canadian Favorites are not included in Rates Export Run Export 05 15 2015 33 34 State Income Tax Sourcing Tool Determine each state s rules for sourcing receipts and properly compute the sales factor when apportioning business income to the state using the State Income Tax Sourcing Evaluator and Chart Builder The Bloomberg BNA State Income Tax Sourcing Evaluator generates client readv reports that compare receipts received bv the companv from certain activities to the state s position on whether the receipts received from those activities are sourced to the state as determined bv the state s responses in the annual Bloomberg BNA Survev of State Tax Departments and an analvsis of state law Use the Chart Builder feature to see which tvpes of receipts must be sourced to each state for purposes of computing its sales factor See page 24 for general information about Chart Builders State Income Tax Sourcing Evaluator Click the New Evaluator tab nam
79. r sales location a warehouse or sales office or soliciting business in the state through the use of or sales office or soliciting business in the state through the use of employees or independent contractors in the state Quill Corp v employees or independent contractors in the state Quill Corp v North Dakota 504 U S 298 1992 see also Natl Bellas Hess Inc North Dakota 504 U S 298 1992 see also Nati Bellas Hess Inc v Illinois Dept of Rev 386 U S 753 1967 v Illinois Dept of Rev 386 U S 753 1967 Withholding Tax Chart Builder PRACTICE TOOLS Go to the International tab to access the Withholding Tax Chart Builder on on the Practice Tools frame The Withholding Tax Chart Builder includes 114 countries and allows you to build a chart displaying the host investor tax liability as outlined in the applicable treaty ies International Tax Chart Builders s Global Tax s International Tax Forms PDF Portfolio Working Papers To build a chart Choose a World Region and Source Country Tax Treaties Choose Withholding Rates for Source Country s VAT Choose Investor Countries and Treaty Rates Withholding Tax Select Chart Display Click Create Chart International Withholding Tax Chart Build a chart covering one or more jurisdictions and one or more topics You must select one Create Chart World Region Source Country and at least one Investor Country to build a chart Once you select jurisdic
80. reatises 132 Estates Gifts and Trusts cee amp Hdd ta fly Folders By Share Split Screen Sores Add the document or search to an existing folder or create a new folder Add additional identifying information as needed and click Submit Choose the folder to place your item in Add to existing folder Create new folder no quotes My Saved Items Vv or mia Enter Item Details Item Name Test Chart Project Name Test Chart Characters left 2000 Note Cancel 8787TTEEET To access the saved file click MY FOLDERS on the menu bar A MY HOMEPAGE SITEMAP PREFERENCES MYFOLDERS ACCOUNTPROFILE GETTING STARTED ABOUT CONTACTUS HELP SIGNOUT To sort by column click a column heading Type Name etc To display the Folder Options drop down menu click the Wheel icon J on the Folders column Right click on the item name to display the Item Options drop down menu To create a note click the Notes icon N in the Notes column enter text and click Submit A Notes icon ES without the plus sign signals a note has been added Click the icon to view the note Mv Folders Show files from the following products Tax and Accounting Center Vv Filter Currently Applied None Folders Iv Folder items Folder Options QI Tvpe Name Project Product DEDANS L C Pre 1977 Tax Rules fo Test Document Tax and Accounting Center 02 11 2015 R Duplicate Q garnishment Test Search Tax and Accounting Center 02 11 2015
81. s Tax Break Makers of propane and hard cider are anang the likely winners as the Senate Finance Committee prepares to wote this week on a package of tax breaks Cider makers would benefit from an expansion ot the detinition at hard cider which is taxed more lightly than wine or champagne The propane measure would lower the excise tax on propane so that it is mo longer taxed at the same rate as more energy dense gasoline More Finding Tools Index Archives a Search Indexes a Browse Indexes Reported Cases a View Alphabetically q View Recent Cases Reported Grassley Reed Bill Would Bar Deductions for Corporate settlements View Documents By a IRC Section ra 4 bipartisan duo of senators introduces legislation ELT designed to pravent corporations from deducting 20 Dailv Tax Report Articles Click the title of an article to access the full text Articles mav include BNA Snapshot Linked svnopsis of the article outlining Kev Decisions and Kev Issues IRS Code Regs or Documents Link to full text Bloomberg BNA Contacts Direct links to the author and editor of an article Reprints amp Permissions Information on how to reprint or use this article outside of your subscription Related Articles Link to corollarv articles on this topic etc Daily Tax Report News Archive Go Wi an Daily Tax Report kar Mh 0 add te My Folders there fm Sclit Screen B debits Mu Folders Gy io Dai
82. s amp Practice Tools Indexes amp Analysis by State Commentary Agency Documents Decisions amp Forms Finding Aids Search Individual Portfolios and Chapters Search Expert Analysis Select collections to search select all deselect all L Fast Answers Accounting CI Health Care Reform Adviser LI Fast Answers Compensation Planning C State Tax Portfolios LI Fast Answers Estates Gifts and Trusts LI Corporate Income Taxes L Fast Answers Federal Tax LI Limitations on Authority to Tax Scroll down the Expert Analysis tab to find the Search Individual Portfolios and Chapters template Select the Portfolio s click Add and utilize any of the optional fields Case Citations Source Citations or Word s Click the Info icon to view specific information about entering data into a field Click SEARCH Search Individual Portfolios and Chapters Note You may search a maximum of five portfolios and chapters Select portfolios and chapters to search Your Current Selections You can double click the options to move them You can double click the options to move them U S INCOME PORTFOLIOS U S INCOME PORTFOLIOS 0 U S Federal Tax Research 340 Pension Accounting Financial Instruments Special Rules 341 Accounting for Share Based Compensation T Taxation of Non Equity Derivatives Taxation of Equity Derivatives U S Taxation of Notional Principal Contracts International Pension Planning International Pen
83. s Search Options Edit Search Within Results Add to My Folders Clear eS p Add to My Folders Share Solit Screen lt GO gt LINKS AND lt GO gt PAGES lt GO gt Links and lt GO gt Pages are accessed through Search Results and cover critical federal state and international tax topics including all 50 states and nearly 115 countries Use Quick Search see page 11 to search all content included in a subscription The lt GO gt Links frame displays with the Search Results list and provides a shortcut to related Tax Management Portfolio analysis Code sections regulations Fast Answers news and more The lt GO gt Links frame also links to the available lt lt GO gt Pages The topical lt GO gt Pages display editor selected topic specific content providing background on key aspects of the topic with links to related Bloomberg BNA content Note Subscription access is required to access content that is linked from lt GO gt Links and lt GO gt Pages Launch a Quick Search see page 11 of all content included in a subscription by entering search terms a tax topic an I R C section country or state in the Quick Search text box lt GO gt Links display next to the Search Results list Find links to lt GO gt Pages in the lt GO gt Links frame or click More to view the lt GO gt Page MYHOMEPAGE SITEMAP PREFERENCES MYPOLDERS ACCOUNTPROFILE GETTINGSTARTED ABOUT CONTACTUS HELP SIGH OUT Text size a Bloomberg Tax a
84. s are fact specific A specific aspectof anactivitv addressed in the survey might vield a different result 1 1 Receipts from the following activities will beincluded in thenumerator of the sales factori T Receipts from Leases Licenses or Rentals of Tangible Personal Propertv1T e Rentals leasesor licensing of tangible personal property located in state for entire period of use 19 Rentals leasesor licensing of tangible personal propertv located in state and out ot state during period of use 24 il Answerper BBNA 2014 Survey of State Tax Departments 2014 Survey Response See Regulation 625 36 Xe and f l California uses the location based sourcing method for receipts from leases licenses or r entals oftangible personal property per the BENA 2014 Survev of State Tax Departments Bloomberg BNA Note See Cal Rev amp Tax Code 25121 Cal Rev amp Tax Code 625128 Cal Rev Tax Code 6 23128 7 2 Answer per BBNA 2014 Survev Analvsis 2014 Survey Response See Regulation 525 136 2 e and f California uses the location based sourcing method for receipts from leases licensesor rentals of tangible State Tax Nexus Tools s Portfolio Working Papers Bloomberg BNA s State Tax Nexus Tools Chart Builder and Evaluator are available for id pi Corporate Income Tax Sales amp Use Tax and Trust Nexus Featuring a one of a kind online Sales and Use Tax Rate Finder database and report genera
85. sion Planning Puerto Plan Selection Pension and Profit Sha Plan Qualification Pension and Profit Specialized Qualified Plans Cash Bala Employee Benefit Plans and Issues for Small E ESOPS Nondiscrimination Testing and Permitted Dispa Pension Plan Terminations Single Empl Tax Code Word s Go To Use Go To to locate a source document tax case or specific Portfolio by citation number or name Templates are arranged by Federal Foreign State and Accounting Click the Info icon for detailed information about how to use the specific frames Note To search the current and archived Code back to 2000 use the Go to a document by citation drop down menus Federal Foreign State Accounting Go to a document by citation Enter one citation and click Go The question mark lists citation formats internal Revenue Code Treasury Regulation Treasury Decision Prop Treasury Regulation Prop Regulation Project IRS Revenue Ruling l ka dieel po IRS Revenue Procedure l aay ee IRS Announcement IRS Notice IRS Publication IRS PLR Go to Expert Ana IRS TA M Enter number or use dropdowns below to navigate to a portfolio or chapter IRS CCA e IRS FSA Selecta US Income Porfolo SSSSSCSCSCSOSSSCCCCCCC LV TP List of U S Income Portfolios IRS FAA TA IRS AM Select an Estates Gifts and Trusts Portfolio GO IRS Chief Counsel Notice List of Estates Gif
86. sonable approach to implementing tax code Sertlon 909 designed to curb such splitters The rules keep the exclusive list of splitter arrangements in the temporary regulations T D 85777 the IAS put forth three years ago with some changes Considering the breadth of Section 909 as enacted this exclusive list approach b a reasonable balance behind Section 09 and the need for administrabla rules John Harrington a partner at Dantons LLP tells Bloomberg ENA More PDF version Annotated IRS Final Regulations on Section 4940H T D 655 Implementing Employer Sharecl Responsibility Provisions Under ACA for 2015 a Latest IRS Chief Counsel Code Subject Matter Telephone Preview of the 114th Congress Preview of the 114th Congress Finance Committee Looks to Advance Low Hanging Fruit With Markup Lawmakers looking ta boost foreign investment in MAI WS real estate will move legislation through the Senate Finance Committee tomorow The measure backed by Sens Enzi and Menendez is one of 17 SSS bills scheduled for markup Others deal with energy leohel and the military among other subjects All the bills represent low hanging fruit that Senate Finance Committees Chairman Hatch Says ha hapes to advance early in the year More xs Directory We welcome your suggestions news tips and article ideas Please contact the managing editor at dir bna com Hard Cider Propane Sectors Poised to Win as Senate Ponder
87. t documents in either Printer friendiv or Rich Text Format RTF text format When printing more than one document select RTF in order to place section breaks between each document Select segment s Click the radio button to choose the Portfolio segments to print The segments displayed below the selected segment are also printed Print or Display your selections To select and deselect documents prior to printing use the linked commands in the print dialog box Click the Print Display Selected Documents button for each frame to launch the print preview function Use the browser s print function to print Source Information The print display opens in a separate window and adds source and contact information to the top and bottom of the document s U S Income Portfolios Natural Resources Go Portfolio Outline Search Options Edit Search Within Results Add to My Folders Clear 4 Go to Hit f Results in U S Income 3 ties Analysis Laws Regs Agency Docs 58 Laws amp Regs Archive 69 Cases 4 0 Add to My Folders Qy Share Results for wind farm Check to add to print selection list b Wind Facility A wind facility is a facility that sa owned by the taxpayer Third it must begin before January 1 20 purposes of the 25D residential IRS has ruled that a partnership i f designing f 28 Portfolio 544 1st Equipment Leasing Substance business of designing manufac and F
88. t of the investor country and is the beneficial owner of the income 2 that the income recipient does not have a permanent establishment in the source country to which the relevant income is connected and 3 that the parties ta the transaction are operating at arm s length except when it is clear that this is mot the cose and that the transaction giving rise to the income does not trigger any treaty anti avoidance provisions The existence of relevant specific anti avoidance rules may be indicated in the explanatory text Note also that Most Favored Nation and other provisions that in response ta future events that occur outside the treaty may change the rate provided in a treaty are not taken into account The chart is intended only ta provide a general guide The relevant domestic law provision and any relevant treaty article should always be consulted i in specific circumstances Tax Calculators Access estimated values for a number of tax related scenarios Tax specific calculators include 1040 Tax 1040 EZ Earned Income Credit Pavroll Deductions and more Retirement Savings amp Planning Insurance Investment and Business calculators are also available Click Tax Calculators on the Practice Tools frame Click a link to open a tax calculator Use the drop down menus and click the signs to display the data entry fields 1040 Tax Calculators are available for tax years 2012 2015 Make the data selections by en
89. tates Gifts and Trusts Journal Index Financial Planning Journal Index Real Estate Journal Index Source Documents Indexes Internal Revenue Code Index Treasury Regulations Index Search Indexes amp Finding Aids A MY HOMEPAGE SITEMAP PREFERENCES MYFOLDERS ACCOUNTPROFILE GETTING STARTED ABOUT Bloomberg Tax and Accounting BNA Follow us on 2 Twitter Ej Facebook EA Sign up for email updates Authors Advisorv Board CONTACTUS HELP SEARCH HISTORY SAVED SEARCHES ADVANCED SEARCH SIGN OUT Textsize AQAWA SAVED CHARTS GUIDED SEARCH GOTO SEARCH My BNA O Federal sk Daily Tax Compensation amp Estate Use Report Benefits Planning Pricing State Sales amp Intemational Transfer Accounting Tax Practice Series Payroll More All Practice Areas Welcome Search this tab GO TO DOCUMENT BY CITATION Internal Revenue Code v Citation Formats More Options EXPERT ANALYSIS List of Portfolios Chapters Set as My Home Page MASTER YOUR TAXES 2015 gt gt FEDERAL TAX GUIDE Your Essential Desk Reference w Indexes TAX FORMS amp GUIDES Tax Forms Interactive Federal Tax Forms PDF Tax Prep Guides 2014 Tax Prep Guides Archive Fast Answers Federal Tax U S Income Portfolios Indexes Keyword IRC i U S Income Portfolios Index o lo ABCD TIKLMN Click on B to expand a heading A REORGANIZATIONS See also CORPORATE REORGANIZATIONS AARs
90. ted Transactions 366 State Taxation of Compensation and Benefits 367 IRAs 368 SEPs and SIMPLEs Qualified Plans Taxation of Distributions Employee Plans Deductions Contributions and Funding 2013 as of 12 31 42012 as of 12 31 2012 2012 as of 12 31 Citation examples 2003 as of 12 31 2 Advanced case search Advanced case search 3002 as of 12 31 2 2002 as of 12 31 2002 2001 as of 12 31 2001 Search History Click Search History on the banner to view up to 90 days of search history To take advantage of this feature be sure to log in to your Account Profile Each listed search includes a date and time stamp To retain a search for future use click Add to My Folders MY HOMEPAGE SITEMAP PREFERENCES MYFOLDERS ACCOUNTPROFILE GETTING STARTED ABOUT CONTACTUS HELP SIGNOUT Textsize T Tax and Accounting Bloomberg BNA SEARCH HISTORY SAVED SEARCHES SAVED CHARTS ADVANCED SEARCH GUIDED SEARCH GOTO Search History Click on a search to re execute it Search es Search garnishment 5191 documents Search Collection s Multiple Collections Transactional Diagrams RELATED 26 usc 102 0 documents Page 1 of 1 Date Last Run WED FEB 11 2015 JAdd to My edit 01 39 PM Folder MON FEB 02 2015 Add to My edit 11 52 AM Folders 13 search Results Search Options Edit Search Within Results Add to My Folders SEARCH RESULTS Search Results are
91. tering the data or using the sliders Make all selections calculate the tax and pana Tax Calculators PRACTICE TOOLS Tables Charts and Lists Quick Tax Reference Client Letters Elections amp Compliance Statements Transactional Diagrams Portfolio Working Papers Tax Practice Series Aids Tax 1040 Tax Calculator Tax Year 2014 1040 Tax Calculator Tax Year 2013 1040 Tax Calculator Tax Year 2012 457 Payroll Deductions Earned Income Credit EIC Calculator Estate Tax Planning Hourly Paycheck Calculator Marginal Tax Rate Calculator Net to Gross Paycheck Calculator Payroll Deductions Section 125 Cafeteria Plan Self Employment Tax Calculator US 1040 EZ Tax Estimator Investment Taxable vs Tax Advantaged Investments REIT Tax Equivalent Distribution Municipal Bond Tax Equivalent Yield Investment Returns Annual Stock Option Grants Stock Option Calculator Lump Sum Present Calculator 1040 Tax Calculator Insurance Fixed Annuity Calculator Variable Annuity Calculator Immediate Annuity Calculator Health Savings Account Contribution Calculator Health Savings Account Goal Calculator Health Savings Account vs Traditional Health Plan Health Savings Account Employer Benefits Business s Like Kind Exchange s Repossession of Personal Property from an Installment Pavment Sale Repossession of Real Propertv Repossession of Personal Propertv from a Deferred Pavment Sale
92. the privilege to prepare Corporation Namej s 2014 Federal Form 1120 and requested state corporate income tax return s for State Names A i Weare I am committed to providing you the highest quality of tax preparation and customer service and look forward to working with you This engagement letter expresses the terms and conditions under which we I will provide you with tax services and outlines responsibilities for both you and us me We I must receive this engagement letter signed and dated prior to our my preparing the corporate tax returns 2 The required state returns may be unknown at the onset of the engagement or it may become evident that additional state returns are necessary after work commences the practitioner may consider using the following language instead Thank you for the privilege to prepare Corporation Name s 2014 Federal Form 1120 and requested state tax return s which will be specifically identified and mutually agreed upon in writing including email throughout the course of the engagement 4 Because state nexus rules can be fairly complicated and involve extensive research when determining if nexus applies to a corporation the practitioner may want to make it clear that the tax preparation services contemplated in this letter do not include a determination as to whether a corporation has fulfilled all of their state filing requirements by including language similar to the following Our my services in
93. tions jurisdictions and categories must match the original export file in order to be imported To add or remove states or topics import your answers first revise the project and then export the file again This will ensure the changes are not lost Click the Import Answers button and Browse to select the Excel file to be imported Click Continue A status box displays following the progress of the upload Click Complete Import State Income Tax Sourcing To lHome Hep w State Income Tax Sourcing Evaluator New Evaluator New Chart Saved Projects My Current Evaluator Import Answers Download Report 1 Receipts from Leases Licenses or Rentals of Devinn VAN litcacn An bf Tangible Personal Property 1 4 af ca Revise Evaluator Collapse All Save Answers Receipts from Leases Licenses or Rentals of Tangible Personal Property 1 4 QUESTION 1 nal property used in the state for the entire rent Special Industry Receipts Banks and Financial Services Companies 0 39 Yesto All NotoAll California New York QUESTION 2 Does your company lease rent or license tangible personal property used both in and outside the state during the rental lease or licensing period California New York Import Answers x Import Answers Upload a previously exported Excel file for this project Note that your imported Uploading MvCurrentEvaluator xisx Cancel answers will overwrite any existing answers for this pro
94. tions and topics choose the display order for the information you wish to display Choose a World Region and Source Country Withholding Rates for Source Country Americas Vv United States of America V w Statutory Rates Dividends m Z Interest D Choose Investor Countries and Treaty W Royalties Rates Expand All Collapse All Select All Items Clear All Items Select Chart Display TOpic headings across top Jurisdictions gt y Europe across top Asia Pacific Americas Create Chart Reset Africa Middle East Treaty Rates to Display v Treaty Rates w Strategic Dividends Portfolio Dividends Specific Kinds of Interest Interest Generally Royalties Y w w w 25 Withholding Tax Chart Builder continued The chart display includes added commentary updating the treaty language To save the chart click Add to My Folders see page 10 Export to Excel to manipulate the data and print Bloomberg Tax and Accounting BNA Center International Withholding Tax Chart Source Country United States of America Topic Dividends 30 in general 0 in the case of a Interest related dividends of regulated investment companies essentially mutual funds which are legally dividends paid out of interest the fund receives and designates as an interest related dividend an exemption that is not available to a 10 or more shareholder of the paying company and that has administrative do
95. tor these tools streamline research on state tax nexus and give users input on ee estes State Tax Chart Builders a wide variety of specific scenarios all validated by state tax departments and citations to primary s 50 State Overview sources The Chart Builder tool creates state by state comparative charts showing each state s nexus LR C Conformity policy See page 24 for information on how to use a chart builder Corporate Income Individual Income i l L l s Sales and Use The Evaluator helps to determine if there is nexus in one or more states with a questionnaire about the Excise types of activities being performed Answers generate a detailed client ready report explaining each Property Estates Gifts and Trusts state s nexus law and showing the nexus consequences of each See State Income Sourcing Tool S I Tax S ing Tool 1 page 34 for information on how to use an Evaluator tool menanam ons State Tax Nexus Tools s Corporate Income Tax Nexus s Sales and Use Tax Nexus s Trust Nexus State Tax Nexus Tools f Home Help w 2 BBNA Editors Sign Out Welcome to the State Tax Nexus Tools Corporate Income Tax Nexus Sales amp Use Tax Nexus Trust Nexus This practice tool allows you to quickly gauge the state income tax nexus implications that certain What You Can Do activities have on a company Select states and activities to evaluate The Bloomberg BNA State Tax Nexus Tools generat
96. ts and Trusts Portfolios IRS News Release C foo IRS Action on Decision List of Foreign Income Portfolios IRS Information Letter C fco IRS PMTA List of Tax Practice Series Chapters IRS LB amp I Industry Guidance i Select a U S Income Portfolio IRS GCM IRS SCA 5 al fa Financial Instruments Special Rules Taxation of Non Equitv Derivatives 188 Taxation of Equitv Derivatives 189 U S Taxation of Notional Principal Contracts 320 International Pension Planning 324 International Pension Planning Puerto Rico 340 Pension Accounting 341 Accounting for Share Based Compensation 350 Plan Selection Pension and Profit Sharing Plans 351 Plan Qualification Pension and Profit Sharing Plans 352 Specialized Qualified Plans Cash Balance Target Age Weighted and Hybrids 353 Employee Benefit Plans and Issues for Small Employers 354 ESOPs 356 Nondiscrimination Testing and Permitted Disparity in Qualified Retirement Plans 357 Pension Plan Terminations Single Employer Plans 358 Cash or Deferred Arrangements 359 Multiemployer Plans Special Rules 360 Qualified Plans IRS Determination Letter Procedures 361 Reporting and Disclosure Under ERISA 362 Securities Law Aspects of Employee Benefit Plans 363 Age Sex and Disability Discrimination in Employee Benefit Plans 364 Qualified Plans Treatment in Mergers Acquisitions and Other Corporate Transactions 365 ERISA Fiduciary Responsibility and Prohibi
97. ttp www bnatax com taxevents Dailv Tax Report The Dailv Tax Report is the comprehensive source for news on kev federal state and international legislative regulatorv and judicial tax related developments including pensions and accounting The Dailv Tax Report provides full text of kev legislative regulatorv and judicial documents Issues are archived for 10 vears Click the Dailv Tax Report tab to access the dailv report Click Customize Topics to select the Topics Courts States and Countries to appear on your Daily Tax Report home page see page 4 To have the Tax and Accounting Center open with Daily Tax Report as the home page click Set As My Home Page Locate Daily Tax Report articles by page number View Daily Tax Report as BNA Highlights headline with abstract All Headlines All Headlines with Summaries headlines plus one sentence summary BNA Insights are authored by tax and accounting experts and offer analysis of key legal legislative regulatory and business developments emphasizing practical implications and trends Tax Core see page 21 From the Editors links to minisites general explanations special reports etc for the trending hot topics in tax and accounting law Daily Tax RealTime updates the Daily Tax Report throughout the day with breaking news Finding Tools are links to indexes and reported cases arranged Alphabetically By
98. umber can oniv include letters and numbers and is case sensitive To secure features like 90 dav search historv and personal folders set a password on vour account LI Human Resources LI Intellectual Propertv LI Set Password for Additional Security C Labor amp Employment Password aa Confirm Password UI Litigation o Marketing amp Business Development 0O Mergers amp Acquisitions U Privacy amp Securities Tax amp Accounting Update Account _ Telecommunications 8 Internet Daily Tax Compensation amp Estate State Sales amp International Transfer Accounting Tax Practice Payroll More All Repo Benefits Planning Use Pricing Series Practice Areas Preferences Daily Tax Report Welcome Set as My Home Page Search this tab Click Customize Topics under the title to aily Tax Report cures RESE select specific content to display on the Daily Tax Report home page Hot Topics Ai Daily Tax RealTime BNA INSIGHTS s Backup Withholding G 20 Officials Pledae Onaoina Work on Profit Shiftina All BNA Insights On the Customize Topics for Daily Tax Report screen make selections for headline display and choose topics courts states and countries of interest to display on the Daily Tax Report home page Customize Topics for Daily Tax Report Make the selection s and click SAVE Articles on your selections e will be shown at the top of your email if you get customized ema
99. umn and lists a cuen Yoi hallu Hadia the options available for a title Sici e gl gt Customize Now Click the Info icon to display descriptive TM Library Weekly State Tax Report XxX information about the available formats O Standard Weekly Headlines O Standard Weekly Highlights Customize Your Weekly Headlines When customization is an option the gt customize now Customize Now button displays Click it and choose the specific topics EI cance courts etc of interest Save to retain all changes Click the X or deselect a title to delete it Click FAQ for detailed instructions TABLE OF CONTENTS Getting Started 00000 General information on accessing the Tax and Accounting Center Email Updates 00000 Sign up for Email Updates Tax Center App 000000 Information on how to access the Tax and Accounting Center on Android and Apple devices Account Profiles Preferences Create an account profile and make Preference selections for the Jax and Accounting Center and the Daily Tax Report Introduction 0000eeneaee Overview of all content included in the Tax and Accounting Center Home PageS 000eeeeeee Highlights of the user friendly home pages Indexes 2 eee ee ees Topical access to all decisional materials and news My Folders 00000eeeaes Save documents charts or searches and easily recall them
100. unting Policy amp Practice Report Indexes Compensation Planning Portfolios Index wl Accounting Policy amp Practice Portfolios Table of Cases Select one or more of the following optional criteria to limit your search Search term s SEARCH Reset Form O Fields Show shared fields only collections O Show fields from all selected ADD TO SEARCH Choose a field v Choose a field enter search terms for the field then click Add to Search 6 Limit by date No Date Restrictions V From To Ex mm dd vvvv Ex mm dd yyyy SEARCH Reset Form Search Operators Use operators to show relationships between search terms Click on an operator to add it to your search Operator Definition and or a blank space and or or or not nat near N within N words in the same sentence in the same paragraph replace one character replace zero or more characters at the end of the term phrase 10 MY FOLDERS Use the My Folders feature to retain a search string or document Log into your ACCOUNT PROFILE in order to use this feature see page 4 To save a search string click Add to My Folders on the Search Options toolbar To save a document or chart click Add to My Folders while viewing the file Go Browse Contents Portfolio Outline Search Options Edit Search Within Results Add to My Folders Clear 4 Go to Hit H Results in U S Income 232 T
101. vigators International Payroll Guides News amp Commentary Federal and State Practice Tools including chart builders Source Documents Tax Advisors Tax amp Accounting Portfolios Tax Forms and Tax Prep Guides Tax Practice Series And much more HOME PAGES Use the tabs to link to all content included in your subscription Each tab has a home page with topic specific collections of content and tools MENU BAR The menu bar is located above the banner and contains links for Site Map Preferences My Folders Account Profile Getting Started About Contact Us Help Sign Out and Text size fi MY HOMEPAGE SITEMAP PREFERENCES MYFOLDERS ACCOUNTPROFILE GETTING STARTED ABOUT CONTACTUS HELP SIGNOUT Textsize On A WA BANNER The banner displays on all pages in the Jax and Accounting Center In addition to the menu bar find the Quick Search text box Search History Saved Searches Saved Charts Advanced Search Guided Search Go To networking links links to Bloomberg BNA Authors the Advisory Board and Search My BNA Quick Search Search in all collections included in your subscription When you are working in a collection the banner displays the added option to search in All or the This Collection or This Portfolio Search Historv Saved Searches Saved Charts Searches are retained in the Search History queue for 90 days Save them to retain a search past 90 days To access a saved sear
102. xcel spreadsheet at the bottom of the chart hed ii al z wechartbuilderxis Read Only Microsoft Excel Home Insert Page Layout Formulas Data Review View Acrobat WinCalendar w 5X canen E Rm all Ea cenen oe es a a A Paste l i Conditional Format Cell Insert Delete Format gota Find amp F E iu a aF FF BH Merge amp Center b IEEJ Formatting 7 as Table Styles j i Clear Filter Select Clipboard wj l w Alignment fa Number Tua Styles Editing fe SOURCE CE COUNTRY UNITED STATES OF AMERICA SOURCE COUNTRY UNITED STATES OF AMERICA DOMESTIC RATES worksheet 2 of report e Domestic Rates tab shows gross tax withholding tax rates under a source country s domestic law for dividends interest and royalties paid to nonresidents of that country If more than one rate may apply to a particular kind of income the text explains when each rate applies If he domestic law rates are impacted by rules of a supra national body most commonly EU Directives and EU instruments that the source ountry hes implemented this is also explained FATT RATES worksheet 3 of report Treaty Rates tab shows gross tax withholding tas rates on various kinds of income that are specified in the source country s treaties ith various investor countries If there is no such treaty this is indicated by the words No tr aty The r
103. xt box as many fields as needed to complete next to Choose a field the search string Advanced Search Select collections to search from the categories below then use the search form to perform your search choose collection s to search Select one or more of the following optional criteria Expand All Collapse All Select All Clear Selected to limit your search Collections EXPERT ANAL YSIS Search term s Be FAST ANSWERS retail lease Reset Form IZ U S INCOME PORTFOLIOS FEDERAL EXCISE TAX NAVIGATOR FEDERAL ADVISERS BOOKS amp TREATISES ESTATES GIFTS AND TRUSTS PORTFOLIOS TAX PRACTICE SERIES FOREIGN INCOME PORTFOLIOS TAX TREATIES ANALYSIS INTERNATIONAL GUIDES STATE TAX PORTFOLIOS f ADD TO SEARCH SALES AND USE TAX PORTFOLIOS STATE GUIDES AND NAVIGATORS search terms for the field then click Add to ACCOUNTING POLICY amp PRACTICE PORTFOLIOS U S GAAP NAVIGATOR PAYROLL ADMINISTRATION GUIDE NEWS AND COMMENTARY W LAWS REGULATIONS AGENCY DOCUMENTS Z CASES AND DECISIONS From To _ PRACTICE TOOLS Ex mm dd yyyy Ex mm dd yyyy TAX FORMS _ INDEXES AND FINDING AIDS _ EVENTS amp TRAINING 11 Guided Search Use preselected fields organized bv content tvpe for searching in specific collection s On the Guided Searches page use Expert Analysis tab templates to search in an individual Portfolio Guided Searches Search options Expert Search News amp Laws Regulations Case
104. y profile information to aform __ click the Apply Profile Information button select the type of profile and click Open To copy a previous year s profiles to the current year s client folders click File and select Copy Profiles The dialog box opens with the path to the previous years forms Click OK Profiles are automatically copied to the current year s folder If identical client names exist information for each client is numbered e g smith2 smith3 and placed in a data folder A confirmation message displays when the process is complete Applving a saved profile to a form automatically transfers the information from the profile to the form File Edit View Document Window Help Copy Profiles PRINT To print a document s select the document s from a full screen display document list or Search Results page The selected documents are displayed in the Print Dialog box To print a single document click the Print icon amp while viewing the document To print multiple documents from the search results list click the checkbox next to each document title to be printed and then click the Print icon ES A maximum of 25 documents can be printed simultaneously Segmented Printing To print segments of Bloomberg BNA analysis legislation and regulations included in the Jax and Accounting Center click the Print icon E next to a segment Print Dialog Box Select a text format Prin

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