Tax publications
Tax professionals in Grant Thornton's National Tax Office and in local offices across the country publish in leading tax journals and offer tax thought leadership in webcasts and seminars. Read our Tax Hot Topics newsletter and browse through our federal Tax Flashes and state and local Tax Alerts to learn more.
Lessons of Oracle: Inconsistencies and changes in reporting inevitable in state taxation, but when must they be reported?
Recently, the Oregon Tax Court denied a motion for partial summary judgment in Oracle v. Oregon Dept. of Rev., a case involving a taxpayer’s inconsistency in classifying income as business or nonbusiness income in two different states. In Oracle, the court ruled that the goal of uniformity under the Uniform Division of Income for Tax Purposes Act does not equate to law. At a time when states themselves impose widely varying requirements for disclosing inconsistencies, the ruling is particularly significant. In this article, Grant Thornton's Giles Sutton, Jamie Yesnowitz and Chuck Jones discuss the differences among state disclosure requirements and the impact that Oracle may have for taxpayers taking nonuniform positions from state to state.
Navigating the IRS's attack on perceived repatriation transactions
Managing the complex tax laws that comprise the United States' anti-deferral rules (e.g., the Subpart F rules) is a critical issue for many U.S. multinational taxpayers. In some cases, IRS projects in recent years have provided helpful guidance, and even relief, for U.S. multinational taxpayers. In other cases, the IRS has determined that action has been necessary to curb certain apparent tax benefits relative to transactions that the IRS perceives to result in repatriations of foreign earnings without the corresponding U.S. tax consequences of a repatriation. The latter situations are the focus of this article by Joe Calianno and Brad Rode.
Partnership terminations – what changes, what doesn’t and what is unclear
Real terminations are distinctively different from fictitious or technical terminations. One must be careful when drawing any conclusions as to whether a technical termination has occurred. A thorough analysis of the transfer that is believed to cause the termination must be made to determine whether a sale or exchange has actually occurred and, if so, whether it was a sale or exchange of a 50% or more interest in both capital and profits. Once it is determined that a technical termination has occurred, then one must be aware of what is deemed to occur and the consequences. As to the consequences, there are areas that do not change, areas that do change and areas that are not clear. Go in-depth on this subject with Grant Thornton's Jerry Williford and Todd Sinnett.
Quasi-governmental entities and governmental immunity from sales and use taxes
The line between state and federal governmental powers and activities versus traditionally "private enterprise" activities has become blurred, as governmental entities are requiring additional control, stricter regulation, "bailout" investment and outright ownership over a variety of ostensibly private businesses. Banks, insurance agencies, investment entities, automobile companies and others that, although subject to state and federal governmental regulation in the past, are now, in many cases, virtually indistinguishable from the government itself in many key ways. Given that there may be a variety of state and local, as well as federal, tax implications regarding the "nationalization" of many businesses that are beyond the scope of this article, what happens when a state or local government attempts to impose a sales and use tax on the purchases of a quasi-governmental entity? Find out in this article by Eric de Moya and Jamie Yesnowitz.
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Congress tees up remaining 2010 tax agenda, but schedule is tight
Congress adjourned for its July 4 recess without completing several major tax priorities. Unfinished business includes tax “extenders,” the expiration of the 2001/2003 tax cuts and more.
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