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State Taxation of Foreign Business Without a Permanent Establishment
Sending employees or representatives into the United States may, as a result, have the unwelcome effect of subjecting a foreign corporation’s worldwide income to state or local tax, on an apportioned basis. Federal tax treaty provisions will not protect foreign … Continue reading
Developments in Multistate Taxation
Phil Tatarowicz and Rebecca Bertothy explain the latest and most important developments in state taxation every month with the Corporate Business Taxation Monthly column, Multistate Taxation. * * * * * This story is from the CCH’s monthly Focus on … Continue reading
Nonrefundable U.S. Withholding Tax Imposed on Foreign Investment Vehicles That Fail to Report
In the current issue of the Journal of Taxation of Financial Products, Vol. 8 No. 4, Steve Kopp and Sharon Kim explain in their article, Nonrefundable U.S. Withholding Tax Imposed on Foreign Investment Vehicles That Fail to Report, that a … Continue reading
Unwinding an S Corporation Leveraged ESOP: A Case Study of a Casualty of the Great Recession
In the Tax Tip column in the Journal of Passthrough Entities, Charles Egerton and Christine Weingart explore ways to unwind an S Corporation leveraged employee stock option plan, many of which have encountered a variety of problems as a result … Continue reading
2010 Plan Amendments and EGTRRA Determination Letter Filing Deadline
Plan sponsors of tax-qualified plans generally update plan documents annually for design and legal changes. In the July, 2010 issue of TAXES – The Tax Magazine, Elizabeth Thomas Dodd and David Levine provide a valuable summary of 2010 plan year … Continue reading