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LexisNexis Tax Center
LexisNexis Tax Advisor – Federal Topical: April 1, 2009 Tobacco Excise Tax Hike Is Dramatic

Tobacco excise taxes increased significantly on April 1, 2009. For example, the rate of tax on cigars (that weigh not more than three pounds per thousand) removed after March 31, 2009, has jumped from the previous rate of $1.828 cents per thousand cigars...

LexisNexis Tax Center
LexisNexis Tax Advisor-Federal Code: IRC Sec. 172(b) Net Operating Loss Carrybacks and Carryovers

The Internal Revenue Service issued Rev. Proc. 2009-19 in March, 2009. Rev. Proc. 2009-19 provides guidance to eligible taxpayers on the election of a 3-, 4-, or 5-year net operating loss carryback for a taxable year beginning in 2008. The provision emerged...

Todd Reinstein
New IRS Prior Period Expenses Safe Harbor for Section 199

This is a brief follow-up to our article last month 1 on the allocation of prior period compensation expenses in a Section 199 allocation. 2 As mentioned in last month’s article, the IRS released a General Legal Advice Memorandum (GLAM) that listed...

Bryan D. Keith
Rescissions Revisited

In Private Letter Ruling 200911004 1 (PLR), the Internal Revenue Service (IRS) ruled that the state law rescission of a merger between two corporations is effective for federal income tax purposes. This ruling continues an IRS trend favoring the rescission...

Locksley A. Rhoden
Offshore Account Amnesty Plan: Look Before You Leap

Although opening a foreign bank account is legal under U.S. tax law, the Internal Revenue Service (IRS) has historically been an opponent of U.S. taxpayers taking their banking activities offshore. That is why U.S. taxpayers should not be fooled by recently...

Elizabeth Pascal
Hodgson Russ Attorney Pascal Admitted to New York State Bar

Elizabeth Pascal is newly admitted to the New York State Bar. Ms. Pascal concentrates her practice in tax law with a focus on New York State, New York City, and multistate tax issues. Prior to joining Hodgson Russ, she served as an intern for Judge William...