State Tax Practice Focused on Foreign Source Income; Criminal & Civil Enforcement

The expanding global economy has increased state taxation of business enterprises that conduct operations on an international level. These business taxpayers are subject to taxation in multiple jurisdictions with diverse laws that have few shared relevant substantive provisions. The U.S. Constitution provides limited restraint on the states' ability to tax these international entities. Legitimate taxation of domestic companies receiving foreign source income by the states is therefore increasing. A new chapter in Bender's State Taxation: Principles and Practice §7.01, available online through the LexisNexis® Tax Center, provides complete analysis on foreign source income taxation, as outlined below.

At the same time, state departments of revenue are directing more attention to the underground economy (a.k.a. the informal, parallel, or shadow economy). In the underground economy, there are very few ways to track transactions in goods, services, or currency. In the absence of accurate federal and state tax return information from operatives in the underground economy, government knowledge is improving and interference with the shadow economy is intensifying. A second new chapter in Bender's State Taxation: Principles and Practice §30.01, available online through the LexisNexis® Tax Center, provides extensive insight into this critical arena of state taxation, as outlined below.

These two new chapters address subject matter that is not comprehensively covered in other state and local tax treatise works:  

CHAPTER 7: STATE TAXATION OF FOREIGN SOURCE INCOME

  • § 7.01 Overview of Taxation of Foreign Source Income

  • § 7.02 The U.S. Constitution and Taxation of Nondomiciliary Corporations Receiving Foreign Source Income

  • § 7.03 The Internal Revenue Code and the Taxation of Foreign Source Income

  • § 7.04 Combined Reporting by a Nondomiciliary Corporation Receiving Foreign Source income -- The Unitary Business

  • § 7.05 Transfer Pricing Overview: What It Is, How It Functions, and Its Impact

  • § 7.06 Taxation of Foreign Source Dividends

  • § 7.07 Factor Representation of Foreign Dividends

  • § 7.08 States' Adjustments to Federal Taxable Income Base

  • § 7.09 Checklist for a Water's Edge Combined Reporting Group

CHAPTER 30: ENHANCED STATE TAX COLLECTION TECHNIQUES AND STATE CRIMINAL TAX ISSUES AND PROCEDURES

  • § 30.01 Introduction -- Combating the Underground Economy

  • § 30.02 State and Local Taxes Used to Combat Underground Businesses

  • § 30.03 Gathering Evidence of Tax Liability and Criminality

  • § 30.04 Tax Enforcement Techniques

  • § 30.05 Contacts With Tax Investigators

  • § 30.06 Criminal Tax Prosecutions

  • § 30.07 Effect of Bankruptcy on State Tax Prosecutions

  • § 30.08 Challenging State Actions Under § 1983 of the Civil Rights Act

  • § 30.09 Conclusion