Taxation of Gains and Losses on Sales of New York Subsidiary Stock

The article focuses on the tax implications of gains and losses from subsidiary sales in New York. The franchise tax on corporations in New York according to Article 9-A of the Tax Law is computed based on the highest in four areas including allocated entire net income, allocated capital, and fixed-dollar minimum tax. The Bausch & Lomb case is presented wherein gains will be taxable and losses will reduce the income in the sale of a subsidiary stock included in a combined return

100% local and organic: closing the protein gap for poultry in the ICOPP Project

A key challenge in improving the sustainability of organic poultry production is meeting the required levels of nutrients from locally sourced organic feeds. 100% organic diets for monogastrics will become compulsory in the EU from 1st January 2015. The ICOPP project brings together knowledge, from 10 EU countries, of local feeds for monogastrics and their wider impact on growth, health and welfare and the environment to identify feeding strategies which comply with organic principles. This poster will report on feeding trials carried out with broilers in the UK by FAI and ORC to investigate the impact of algae, peas and lupins on broiler performance and welfare

Factors to be Considered in Determining a Corporation\u27s Commercial Domicile

Laws can vary significantly in taxing multijurisdictional companies depending on a company\u27s degree of corporate presence in the taxing state, the type and source of income earned, and the type of property used or held in the state. Several critical factors can determine a company\u27s tax liability in a state, including the location of the company\u27s commercial domicile. The US Supreme Court\u27s decision in the Wheeling Steel case regarding commercial domicile is overriding in federal, as well as state courts. Accordingly, multistate companies and their tax advisors should consider the location of central management activities when planning to start or expand a business. Other factors contributing to the determination of commercial domicile also should be reviewed in considering locations for production, administration, and sales functions, in order to minimize the overall tax burden

Share Loans Under IRS Microscope

In a recently released Coordinated Issue Paper (LMSB-04-1207-077), the IRS underscored how its examinations will home in on a once-favored strategy for monetizing stock gains while deferring capital gains taxes. In doing so, the Service reiterated its legal basis for why a variable prepaid forward contract (VPFC) that includes a share lending agreement (SLA) results in a currently taxable sale

Synergistic Effect on CO2 Capture by Binary Solvent System

CO2 absorption into a binary solvent system was studied using a batch‐mode gas/liquid absorption apparatus. The binary system composed of potassium carbonate (K2CO3) and piperazine (PZ) showed a strong synergistic effect, whereby the binary solvent performed better than either of the individual solvents for CO2 absorption. The other pairs of solvents tested (K2CO3/monoethanolamine (MEA) and K2CO3/NaOH) showed no synergistic effects. The results indicate that this synergistic effect only occurs with specific pairs of solvents. The mechanism for the synergistic effect is postulated that the activated CO2 on PZ migrates to K2CO3, or a more reactive intermediate complex between K2CO3 and PZ is formed

Revised Innocent Spouse Rules Offer Greater Tax Relief

When a married couple files a joint tax return, both spouses become jointly and severally liable for the income taxes due, including any additional taxes, interest, and penalties determined at a later date. In the event of an underpayment of income tax, the IRS can proceed against either spouse to collect the entire tax deficiency. This places a spouse in a precarious position in situations where the other spouse deliberately omits income or overstates deductions on a jointly filed income tax return, even if the spouse is totally unaware of the other\u27s transgressions. Relief from joint and several liability is available to spouses that signed and filed a joint return for the year in which an income tax deficiency is assessed and who satisfy requirements under one of the following 3 areas: 1. innocent spouse relief under section 6105(b), 2. separate liability relief under section 6015(c), or 3. equitable relief under section 6015(f)

Emerging New Types of Absorbents for Postcombustion Carbon Capture

Carbon capture is the most probable technology in combating anthropogenic increase of CO2 in the atmosphere. Works on developing emerging absorbents for improving carbon capture performance and reducing process energy consumption are actively going on. The most worked‐on emerging absorbents, including liquid‐liquid biphasic, liquid‐solid biphasic, enzymatic, and encapsulated absorbents, already show encouraging results in improved energy efficiency, enhanced CO2 absorption kinetics, increased cyclic CO2 loading, or reduced regeneration temperature. In this chapter, the latest research and development progress of these emerging absorbents are reviewed along with the future directions in moving these technologies to higher‐technology readiness levels

The Impact of Coal and Biomass Co-Firing on the Economy of Power Plant Carbon Capture

A detailed economic evaluation was carried out to determine the impact of biomass and coal co-firing on power plant carbon capture by methods of plants equipment designing factors and performance, and the sum up of the associated breakdowns of CAPEX and OPEX. Based on the assumptions of the CO2 neutrality of biomass and likely governmental incentives to reduce CO2 emissions, the study results show that biomass and coal co-firing would result in both lower cost of carbon avoided (carbon capture) and lower incremental cost of electricity generation when MEA solvent carbon capture is applied. Two scenarios for co-firing with carbon capture, 30% biomass blending and 90% or 60% CO2 capture from stack, indicate different preference depending on lower or higher incentives

Retirement Plan Contributions and Withdrawals

Qualified retirement plans provide for tax deferral, but they are also subject to a 15% excise tax on excess distributions or accumulations, potentially higher marginal income tax rates on plan withdrawals, mandatory contributions for employers, estate taxes at death, and possible substantial income tax liability for plan beneficiaries. Three possible planning strategies to optimize return on funds available for contributions to a qualified plan include investment in alternative assets, lifetime gifts, and accelerated plan withdrawals. While the 3-year suspension of excess distribution excise taxes under the Small Business Job Protection Act may favor plan withdrawals, in certain situations participants are often best served by leaving the full amount in the plan to take advantage of the tax deferrals