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May 9,  2008

Federal Headlines


Farm Bill Negotiators Announce Final Agreement

 

House and Senate negotiators announced on May 8 that they have reached a final conference agreement on the Food, Conservation, and Energy Act of 2008 (HR 2419). The comprehensive farm policy bill includes a host of agricultural tax provisions that were negotiated by House Ways and Means Committee Chairman Charles B. Rangel, D-N.Y., and Senate Finance Committee (SFC) Chairman Max Baucus, D-Mont. Despite what looks to be substantial bipartisan and bicameral support, the bill has generated a veto threat from the President Bush. House Majority Leader Steny Hoyer, D-Md., said the farm bill conference report is likely to come to the House floor on May 14.

 

According to information released by the SFC, the farm bill would update the agricultural tax-exempt bonds program for loans to first-time farmers and ranchers. It would also exempt from self-employment taxes any Conservation Reserve Program payments made to retired or disabled individuals. The farm bill also would provide a tax credit to help defray the cost of criminal activity associated with agricultural chemicals or pesticides, create a uniform depreciation period for race horses, and allow tax free exchanges of stock that represent a holding of water rights, just as allowed for real property under Code Sec. 1031. The bill also provides temporary tax relief to victims of tornados and storms in Greensburg, Kansas.

 

Negotiators also included a provision intended to provide a boost to the development of cellulosic biofuels, paid for by reducing the tax credit for ethanol. The bill includes a five-year production tax credit for up to $1.01 per gallon at a cost of $403 million over ten years. The bill would reduce the 51-cents-per-gallon credit for ethanol by 6 cents, which would generate $1.203 billion over the next 10 years. The farm bill also includes an extension of the tariff on imported ethanol through 2010, an exclusion of denaturant from the alcohol fuels credit, and a duty drawback on certain imported ethanol, according to the finance committee release.

Veto Threat

 

President Bush will veto the farm bill because it does not provide meaningful program reform and expands the size and scope of the federal government, according to Agriculture Secretary Ed Schafer. "At a time of record farm income, Congress decided to further increase farm subsidy rates, qualify more people for taxpayer support, and move programs toward more government support," Schafer said in a written statement on May 8.

 

By Stephen K. Cooper and Paula Cruickshank, CCH News Staff

SFC Release: 2008 Farm Bill Tax Package --Homegrown Energy Independence

SFC Release: 2008 Farm Bill Tax Package --Farm Tax Reforms

 

House Approves Housing Tax Measure

 

On May 8, the House overwhelmingly approved the tax relief measures included in the American Housing Rescue and Foreclosure Prevention Bill of 2008 (HR 3221). By a vote of 322 to 94, the House approved an amendment to HR 3221 that included provisions of Ways and Means Committee Chairman Charles B. Rangel's, D-N.Y., Housing Assistance Tax Bill of 2008 (HR 5720). Rangel said the bill includes tax incentives to help first-time homebuyers as well as taxpayers struggling to keep their homes from foreclosure. "Congress has acted to strengthen the housing market and provide relief for those struggling in the current economic downturn," Rangel said.

 

The measure includes tax provisions to boost the construction of affordable, multifamily housing through changes to the low income housing tax credit and tax exempt bond programs. In addition to the tax provisions that passed Ways and Means in late April, Democrats included a provision to provide better coordination between housing tax credits, multifamily housing bond programs and other housing programs under the Department of Housing and Urban Development and the Rural Housing Service.

Veto Threat

 

President Bush has threatened to veto the housing package in its current form, contending the bill amounts to a bailout for lenders and speculators. "Congress should send the president the legislation he called for --to modernize the Federal Housing Administration and reform oversight of Fannie Mae and Freddie Mac," White House Deputy Press Secretary Tony Fratto said on May 8.

 

By Stephen K. Cooper and Paula Cruickshank, CCH News Staff

House Ways and Means Committee Release: House Passes Bipartisan Housing Package

 

Additional Guidance for Public Inspection of Form 990-T Provided

 

The IRS has issued additional interim guidance regarding the Form 990-T, Exempt Organization Business Income Tax Return public disclosure requirement under Code Sec. 6104. The guidance reflects the amendments to Code Sec. 6104(b) and (d) by the Tax Technical Corrections Act of 2007 (P.L. 110-172). As revised, the language of Code Sec. 6104(d)(1)(A)(ii) clearly provides that charities must make available for public inspection and copying only those returns filed under Code Sec. 6011 that relate to the organization's unrelated business income tax.

 

Thus, schedules, attachments, and supporting documents filed with Form 990-T that do not relate to the imposition of unrelated business income tax are not required to be made available for public inspection and copying. Additionally, charities must make Forms 990-T available for public inspection and copying only for the three-year period beginning on the last day prescribed for filing such return. All remaining provisions of Notice 2007-45 shall continue in full force and effect.

 

The IRS invites comments on implementation of these public inspection requirements, including comments with respect to those schedules or attachments that should not be available for public inspection when attached to Form 990-T. Comments may be sent via regular mail, hand delivery, or email to the addresses provided in the notice.

 

Section 3 of Notice 2007-45, I.R.B. 2007-22, 1320, is modified

Notice 2008-49, 2008FED ¶46,426

Other References:

 

Code Sec. 6104

 

CCH Reference - 2008FED ¶36,911.10

 

Tax Research Consultant

 

CCH Reference - TRC EXEMPT:12,258.05


Clarifying Amendments to Rules on Transfers of Assets or Stock Following Reorganization Issued (T.D. 9396)

 

The IRS has issued clarifying amendments (T.D. 9361) to the rules regarding the effect of certain transfers of assets or stock on the continuing qualification of such transactions as reorganizations under Code Sec. 368(a). The regulations apply to transactions occurring on or after May 9, 2008, but do not apply to any transaction that occurs pursuant to a written agreement that is binding before May 9, 2008, and at all times after that.

 

Under prior Reg. §1.368-2(k), a reorganization was not disqualified or recharacterized by subsequent transfers of assets or stock if the continuity of business enterprise (COBE) requirement was satisfied and the transfers qualified as distributions or other transfers. These final regulations clarify that transfers to former shareholders (other than the acquiring corporation) of the acquired corporation or the surviving corporation, do not qualify as distributions to the extent they constitute consideration for the shareholders' proprietary interests in either the acquired corporation or the surviving corporation. Such transfers call into question whether the underlying transaction satisfies the continuity of interest requirement as well as certain statutory limitations on permissible consideration (i.e., the "solely for voting stock" requirement set forth in Code Sec. 368(a)(1)(B) or (C). Accordingly, such transfers are outside the scope of the safe harbor protection afforded by these final regulations. However, this safe harbor continues to apply to transfers to former shareholders that do not constitute consideration for their proprietary interests, such as certain prorated dividend distributions by the acquiring corporation following a reorganization. Further, the regulations continue to provide safe harbor protection to certain "upstream" reorganizations followed by a transfer of acquired assets.

 

These final regulations also clarify that safe harbor protection does not apply to a transfer by the former shareholders of the acquired corporation (other than the acquiring corporation) or the surviving corporation, of consideration initially received in the potential reorganization to the issuing corporation or a person related to the issuing corporation. In addition, these final regulations clarify that a transfer does not qualify as a distribution if the acquired corporation, the acquiring corporation, or the surviving corporation, terminates its corporate existence as part of the transfer.

T.D. 9396, 2008FED ¶47,032

Other References:

 

Code Sec. 368

 

CCH Reference - 2008FED ¶16,752

 

Tax Research Consultant

 

CCH Reference - TRC CCORP: 24,060

CCH Reference - TRC REORG: 9,062.05

 

IRS Adopts Final Regulations Regarding Assumption of Liabilities Exception (T.D. 9397)

 

Final regulations have been adopted relating to the assumption of liabilities exception under Code Sec. 358(h). Code Sec. 358(h) provides that, after application of Code Sec. 358(d), the basis in stock received in a nonrecognition transaction shall be reduced to the fair market value of the stock by the amount of any liability assumed in the exchange.

 

Temporary regulations were published in 2005 (NPRM REG 106736-00) and provided that the exception under Code Sec. 358(h)(2)(B) (for transfers of substantially all of the assets associated with the liability) does not apply to an exchange occurring on or after June 24, 2003. The IRS and the Treasury Department determined that removing the exception to Code Sec. 358(h) was necessary to prevent abuse. The final regulations adopted the provisions of the proposed regulations with no change and the corresponding temporary regulations were removed. Reg. §1.358-5 provides that the exception under Code Sec. 358(h)(2)(B) does not apply to an exchange occurring on or after May 9, 2008. For exchanges occurring on or after June 24, 2003, and before May 9, 2008, taxpayers are referred to Reg. §1.358-5T.

T.D. 9397, 2008FED ¶47,033

Other References:

 

Code Sec. 358

 

CCH Reference - 2008FED ¶16,552E

 

Tax Research Consultant

 

CCH Reference - TRC CCORP: 3,202.10


State Headlines


Iowa --Sales and Use, Property Taxes: State Sales Tax Rate Increased; Local Option Tax Repealed

 

The Iowa state sales and use tax rate is increased from 5% to 6% and the school infrastructure local option tax (SILO) is repealed.

 
State Sales and Use Tax Rate

 

The 6% state sales and use tax rate is applicable to:

 

-- sales of tangible personal property sold at retail in the state;

 

-- the sale or furnishing of gas, electricity, water, heat, pay television service, and communication service, including the sales price from such sales by any municipal corporation or joint water utility that furnishes such items or services to the public in its proprietary capacity, except as otherwise provided, when sold at retail in the state to consumers or users;

 

-- the sales price of all sales of tickets or admissions to places of amusement, fairs, and athletic events except those of elementary and secondary educational institutions, the sales price of entry fees or like charges imposed solely for the privilege of participating in an activity at a place of amusement, fair, or athletic event (unless the sales price of tickets or admissions charges for observing the same activity are taxable), and that part of private club membership fees or charges paid for the privilege of participating in any athletic sports provided club members;

 

-- the sales price derived from the operation of all forms of amusement devices and games of skill or chance, raffles, and bingo games, as defined, and card game tournaments conducted, as specified, that are operated or conducted within the state;

 

-- the sales price of furnishing services, as defined;

 

-- the sales price from the sales, furnishing, or service of solid waste collection and disposal service;

 

-- the sales price from sales of bundled transactions; and

 

-- the sales price from any mobile telecommunications service that Iowa is allowed to tax under the provisions of the federal Mobile Telecommunications Sourcing Act, P.L. 106-252.

 

The 6% state sales and use tax rate is reduced to 5% effective January 1, 2030.

 

The legislation specifies that it is the General Assembly's intent that the increase in the state sales, services and use taxes, as specified, from 5% to 6% on July 1, 2008, be used solely to provide revenues to local school districts to be used solely for school infrastructure purposes or school district property tax relief.

 
School Infrastructure Local Option Tax (SILO)

 

After July 1, 2008, all local sales and services taxes for school infrastructure purposes imposed under chapter 423E are repealed. After that date, a county no longer has the authority under chapter 423E or any other provision of law to impose or extend the SILO. According to the legislation, the state sales and use tax rate increase from 5% to 6% will replace the repeal of the SILO. Formerly, local jurisdictions could impose a SILO of up to 1%. According to the Fiscal Note, all 99 Iowa counties approved the SILO and 24 counties authorized extensions of the SILO as of December 2007. The provisions that repeal the school infrastructure local option tax and create the "Secure An Advanced Vision for Education Fund" are repealed effective December 31, 2029.

 
Construction Contractors

 

Construction contractors may apply to the Iowa Department of Revenue for a refund of the additional 1% tax paid due to the increase in the sales and use taxes from 5% to 6% for taxes paid on goods, wares, or merchandise under the following conditions:

 

-- the goods, wares, or merchandise are incorporated into an improvement to real estate in fulfillment of a written contract fully executed prior to July 1, 2008 (the refund is inapplicable to equipment transferred in fulfillment of a mixed construction contract);

 

-- the contractor paid to the Department or the retailer the full 6% tax; and

 

-- the claim is filed on forms provided by the Department and is filed within one year of the date the tax was paid.

 

A contractor who makes an erroneous refund application is liable for payment of the excess refund paid plus interest. In addition, a contractor who willfully makes a false refund application is liable for a penalty equal to 50% of the excess refund claimed.

H.F. 2663, Laws 2008, effective July 1, 2008; Fiscal Note, Fiscal Services Division, Legislative Services Agency, March 26, 2008.

 

Louisiana --Corporate, Personal Income Taxes: State Conforms to ESA Depreciation

 

A bulletin released by the Louisiana Department of Revenue states that because Louisiana piggy backs federal depreciation for both corporate and individual income taxes, the depreciation and expense benefits available under the Economic Stimulus Act of 2008 (ESA) will automatically apply on the state income tax return. The ESA provides business incentives that include a special depreciation allowance of fifty percent for 2008 purchases and increases the expense limitation for small businesses for tax years beginning in 2008.

Revenue Information Bulletin No. 08-008, Louisiana Department of Revenue, May 6, 2008, ¶202-134

 

Other References:

 

Explanations at ¶10-055

 

Explanations at ¶15-045


Wisconsin --Corporate, Personal Income Taxes: Reminder Issued on Tax Shelters Program Deadline

 

The Wisconsin Department of Revenue has issued a personal income and corporation franchise and income tax reminder that May 31, 2008, is an important deadline under the state's tax shelters program. In order to avoid penalties (including stringent new penalties relating to reportable transactions), taxpayers who used a tax shelter to reduce a Wisconsin income or franchise tax liability, increase a loss or credit carryforward, or avoid the filing of Wisconsin income or franchise tax returns must file Form WI-VCP and pay any additional tax due by May 31, 2008. This program applies to taxable years beginning on or after January 1, 2001 and before January 1, 2007.

 

In addition, taxpayers who were required to file federal Form 8886 to disclose a reportable or listed transaction to the Internal Revenue Service (IRS) must provide a copy of the form to the Department by May 31, 2008, if they have not already done so by attaching it to their Wisconsin return. However, for these past years, penalties for failure to disclose will not apply if the reportable transaction is not a listed transaction and there is no understatement of tax. Material advisors who were required to file Form 8264 to disclose a reportable transaction to the IRS must provide a copy of the form to the Department by May 31, 2008, if the transaction is a listed transaction. This includes transactions that the U.S. Secretary of the Treasury determined to be tax shelters under IRC §6111 prior to its amendment by the American Jobs Creation Act (enacted October 22, 2004) and subsequently identified as listed transactions. These disclosure requirements apply only if the taxpayer was otherwise required to file a Wisconsin income or franchise tax return for the year in which the transaction took place.

 

The reminder also notes that there are ongoing requirements for taxpayers and material advisors to disclose reportable transactions for taxable years beginning on or after January 1, 2007. Taxpayers and their material advisors must provide the Department with copies of the federal forms they used to disclose reportable transactions (Form 8886 for taxpayers and Form 8264 or 8918 for material advisors), within 60 days of the date required for federal income tax purposes.

 

Subscribers to CCH Tax Research NetWork can view the complete text of the reminder.

Notice, Wisconsin Department of Revenue, May 8, 2008.

 

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