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December 24, 2008

Federal Headlines


President Signs Pension Bill

 

President Bush on December 23 signed the Worker Retiree and Employee Recovery Act of 2008 (HR 7327). The bill provides temporary relief to businesses from pension funding requirements under the Pension Protection Act of 2006 (P.L. 109-280). The Bush administration had raised concerns about delaying pension funding requirements on the premise that it would increase the cost of near-term claims on the Pension Benefit Guaranty Corporation, according to a White House spokesman. Despite concerns about the bill, White House Deputy Press Secretary Tony Fratto said the administration concluded that "the benefits of the legislation outweighed our objections," particularly given current economic conditions.

 

The House and Senate on December 10 and December 11, respectively, approved the pension technical corrections bill by unanimous consent (TAXDAY, 2008/12/12, C.1). Passage of the measure came as House leadership dropped objectionable tax breaks advanced by Senate Democrats, forcing the Senate to approve a clean bill.

 

Provisions in the bill change current law to provide tax relief for seniors age 70-1/2 or older who are required to take distributions from their retirement plans during the current market crisis. Another measure gives generally healthy multi-employer pension plans that were hurt by the decline in the stock market the ability to avoid drastic contribution increases and cutbacks in worker benefits.

 

Additional provisions in the bill will allow single-employer pension plans to account for expected and unexpected earnings in addition to contributions and distributions when determining the value of the plan's assets. Those plans that fall below the set target funding percentage for a particular year will be required to fund up to the specified funding percentage for that year, instead of 100 percent. Other provisions in the bill were also included in the Pension Protection Technical Corrections Act of 2008 (HR 6382), originally passed by the Senate in December 2007, and the House in March and July of 2008.

 

By Paula Cruickshank, CCH News Staff


Deduction for In Vitro Fertilization Expenses Denied in Absence of Medical Condition (Magdalin, TCM)

 

A taxpayer was denied a Code Sec. 213 medical expense deduction for in vitro fertilization (IVF) expenses incurred in fathering two children. The taxpayer was a fertile man who used IVF for non-medical reasons. He had no physical or mental condition that prevented him from procreating without the use of IVF technologies. The expenses were not, therefore, incurred for the treatment of a medical condition or for the purpose of affecting any structure or function of the body. Under Code Sec. 262, they constituted non-deductible personal expenses.

W. Magdalin, TC Memo. 2008-293, Dec. 57,629(M)

Other References:

 

Code Sec. 213

 

CCH Reference - 2008FED ¶12,543.42

 

Code Sec. 262

 

CCH Reference - 2008FED ¶13,603.945

 

Tax Research Consultant

 

CCH Reference - TRC INDIV: 39,052

CCH Reference - TRC INDIV: 42,074.20

CCH Reference - TRC INDIV: 42,074.40

 

State Headlines


New Jersey --Sales and Use Tax: SST Conformity Updated

 

Legislation has been enacted that amends New Jersey sales and use tax laws to conform with various changes to the Streamlined Sales and Use Tax (SST) Agreement.

 
Fur Clothing

 

The bill repeals the 6% gross receipts tax on retail sales of fur clothing and replaces it with a 7% sales and use tax on "fur clothing" as that term is defined in the Agreement.

 
Telecommunications

 

The legislation revises and replaces current telecommunications definitions with the defined terms provided under the Agreement. Specifically, the bill does the following:

 

-- replaces the current sales and use tax definition of "telecommunications"" with a more specific, narrowly focused definition of "telecommunications services;"

 

-- redefines "intrastate" and "interstate" telecommunications;

 

-- revises "pre-paid calling" and "mobile telecommunications" services definitions; and

 

-- incorporates a series of previously undefined terms, including "international telecommunications," "ancillary service," "directory assistance," and "voice mail service," into the statute of defined terms.

 

The bill also eliminates the current statutory language imposing tax on mobile telecommunications and certain prepaid calling services, and explicitly imposes tax on telephone answering and radio subscription services. These changes do not extend the base of the sales and use tax to new services or omit previously taxed telecommunications from coverage.

 

In addition, the bill makes certain other telecommunications changes that allow New Jersey to incorporate SST provisions within the state's existing telecommunications framework. These changes include:

 

-- the adoption of the SST administrative rule for unbundling taxable and nontaxable components of a sale of mixed telecommunications services;

 

-- the clarification of imposition of use tax on radio subscription services;

 

-- the reorganization of the telecommunications definition that requires the deletion of a use tax measurement rule for prepaid calling services;

 

-- a provision to make explicit the "purchase for resale" exemption for purchases of telecommunications services for use as a component part of telecommunications services provided to a final end user;

 

-- an exemption for certain "in house" use of telecommunications services; and

 

-- a full exemption for receipts from coin-paid sales of telecommunications services using pay phone devices.

 
Other Changes

 

The bill also does the following:

 

-- amends the direct mail definitions to allow for the continuation of taxation on mail processing services;

 

-- eliminates the differentiation between sales of food, food ingredients, and dietary supplements sold in liquid or solid form;

 

-- narrows a broad limitation affecting all medical equipment to affect only certain medical supplies, while limiting the exemption for mobility enhancing equipment to that sold by prescription;

 

-- modifies the definition of "sales price" to codify the current policy on the effect of coupons and rebates;

 

-- incorporates use tax provisions for delivery charges made by a seller; and

 

-- repeals the multiple points of use (MPU) exemption.

 
Technical Revisions

 

The bill makes certain technical modifications to eliminate inconsistencies and clarify omissions related to previous statutory revisions. These modifications and clarifications extend to:

 

-- the research and development exemption to explicitly include receipts from sales of digital property;

 

-- the business prewritten software exemption to eliminate contradictory language concerning prewritten computer software delivered electronically;

 

-- administrative provisions regarding tax records to lengthen the time period for maintaining tax records from three to four years;

 

-- an extension of the current hold harmless provisions for vendors to certain purchasers who rely on tax rates, boundaries, or the taxability matrix provided by the state; and

 

-- administrative provisions concerning the collection and return of tax to stipulate the process of collecting and providing returns for tax imposed on charges in the nature of initiation and membership fees and dues, as well as charges for parking, storing, or garaging motor vehicles.

 

Subscribers to CCH Tax Research NetWork can view the Senate Budget and Appropriations Committee Statement.

 

Ch. 123 (A.B. 3111), Laws 2008, effective December 19, 2008, applicable January 1, 2009; Senate Budget and Appropriations Committee Statement, December 11, 2008

 


Texas --Corporate Income Tax: Various Business Margin Tax Rules Amended

 

The Texas Comptroller has amended several of the revised franchise tax rules, effective January 1, 2009. The majority of the amendments involve merely clarifying portions of the existing rules.

 

34 TAC §3.584 has been amended and expanded to clarify under what circumstances no tax is due and which reports must be filed when no tax is due. Language is added to clarify that combined groups and entities that have tax due of less than $1,000 are not qualified to file a No Tax Due Information Report.

 

An amendment to 34 TAC §3.585 adds that a separate entity that was included in a combined report originally due in the previous calendar year may not use the 100% extension option. The rule has also been amended to clarify that a combined group is required to make its franchise tax payments by electronic funds transfer if any member of the combined group receives notice of the requirement. The rule is further amended to correct the due date of the first extension for entities that are required to make franchise tax payments by electronic funds transfers to August 15. A subsection is amended to add that a separate entity that was included in a combined report originally due in the previous calendar year may not use the 100% extension option.

 

34 TAC §3.587 now states that only expenses excluded from total revenue may not be included in the determination of the cost of goods sold or compensation. Language that did not allow costs related to excluded revenue to be included in the determination of the cost of goods sold or compensation has been deleted. The rule has been expanded to clarify the reporting process for entities in a tiered partnership arrangement that choose to file under the tiered partnership provision.

 

Language has been added to 34 TAC §3.589 to clarify that the $300,000 per person limit on wages and cash compensation is per 12-month period on which the tax is based.

 

Amendments to 34 TAC §3.590 clarify that insurance companies that are subject to the gross premiums tax are exempt from payment of the franchise tax and that a combined group may not include any exempt entity. Additionally, the rule now notes that members of a combined group with different accounting periods must prepare a separate income statement based on federal income tax reporting methods, not the books and records of the taxable entity as originally noted. Furthermore, language has been clarified to state that a combined group is only required to file annual reports. Members of a combined group that join or leave the combined group during the accounting period may be required to file separate initial, annual, and final reports.

34 TAC §3.583, through 34 TAC §3.585, 34 TAC §3.587, 34 TAC §3.589 through 34 TAC §3.590, 34 TAC §3.592, and 34 TAC §3.594, Texas Comptroller of Public Accounts, December, 2008, effective as noted

 

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