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February 5, 2010

Federal Headlines


Senate Democrats Plan to Move Jobs, Tax Breaks Legislation

 

Senate Democratic leaders plan to bring a jobs-related bill to the floor during the week beginning February 8 that would include targeted small business tax breaks in addition to extending unemployment insurance and COBRA benefits. The February 4 announcement was short on details but the measure is expected to provide a job-creation tax credit for employers adding new employees in 2010 and an expansion of small business expensing rules.

 

The tax breaks were drafted by the Senate Finance Committee although a formal markup is not expected. Instead, Senate Majority Leader Harry Reid, D-Nev., will bring the bill to the floor on February 8 with an eye on final passage before lawmakers leave for the President's Day recess, which begins on February 15.

 

The measure also includes streamlining the Small Business Administration lending rules to make loans more accessible and energy-efficiency rebates for homes and businesses, which has been informally dubbed a "cash for caulking" program. In addition, there are provisions to provide bonds for local government infrastructure projects and to extend surface transportation authorization.

 

The bill faces an uncertain future as no Senate Republicans have backed the plan and House Democratic leaders remain wary of the Senate's jobs agenda, which differs in its priorities and involves moving smaller bills over a period of time. The House narrowly approved a $154-billion jobs package (HR 2847) on December 16, 2009 (TAXDAY, 2009/12/17, C.1).

 

By Jeff Carlson, CCH News Staff


IRS Offers Tax Tips for Disabled Persons (Tax Tip 2010-24)

 

The IRS has issued its "Seven Tax Tips for Disabled Taxpayers," which lists tax credits and benefits available to certain disabled taxpayers and taxpayers with a disabled family member:

 

Higher standard deduction for the legally blind;

 

Exclusion from gross income of disability-related payments;

 

Business expense deduction for Impairment-related work expenses;

 

Credit for the elderly or disabled;

 

Deduction of medical expenses for taxpayers who itemize;

 

Earned income tax credit; and

 

Child or dependent care credit.

 

See IRS Publications 3966 and 907, for more information on tax credits and benefits for disabled persons.

IRS Tax Tip 2010-24 --Seven Tax Tips for Disabled Taxpayers

 

Treasury Security Rate Set for Computing Current Plan Liability for February 2010 (Notice 2010-20)

 

For pension plan years beginning in February 2010, the IRS has released the corporate bond weighted average interest rate, the permissible range of interest rates used to calculate current plan liability and to determine the required contribution under Code Sec. 412(l) for plan years through 2010, and the current corporate bond yield curve and related segment rates for the purpose of establishing a plan's funding target under Code Sec . 430(h)(2).

 

The corporate bond weighted average interest rate for plan years beginning in February 2010 is 6.41 percent; and the 90-percent to 100-percent permissible range is 5.77 percent to 6.41 percent. The annual rate of interest on 30-year Treasury securities for January 2010, used to determine the minimum present value of a participant's benefit under Code Sec. 417(e)(1) and (2), is 4.60 percent.

 

The three 24-month average corporate bond segment rates applicable for February 2010 under the election of Code Sec. 430(h)(2)(G)(iv) are: 4.51 for the first segment; 6.64 for the second segment; and 6.75 for the third segment.

 

The transitional rule of Code Sec. 430(h)(2)(G) does not apply to plan years starting in 2010. Therefore, for a plan year starting in 2010 with a lookback month to February 2010, the funding segment rates are the three 24-month average corporate bond segment rates applicable for February 2010, without blending for the transitional period.

 

For plan years beginning in 2010, the minimum present value transitional segment rates for January 2010 are: 3.23 for the first segment; 5.22 for the second segment; and 5.72 for the third segment.

Notice 2010-20, 2010FED ¶46,274

Other References:

 

Code Sec. 401

 

CCH Reference - 2010FED ¶17,730.40

 

Code Sec. 412

 

CCH Reference - 2010FED ¶19,125.505

 

Code Sec. 417

 

Code Sec. 430

 

CCH Reference - 2010FED ¶20,161.30

 

Tax Research Consultant

 

CCH Reference - TRC RETIRE: 15,304.05

CCH Reference - TRC RETIRE: 15,304.10

CCH Reference - TRC RETIRE: 30,556

 

 

NON: FTD01 20100205-I.2 http://tax.
 


 

State Headlines


Oklahoma --Multiple Taxes: Proposed FY 2011 Budget Includes Various Tax Provisions

 

Among other items and recommendations, Oklahoma Gov. Brad Henry's recently released budget for fiscal year 2011 includes a number of income, franchise, sales and use, motor fuels, and tobacco products tax proposals. These tax proposals are briefly addressed below.

 
Income Tax Proposals

 

Repeal and reform of credits: Under the proposed budget, the corporate and personal income tax credit for investments in qualified small business capital companies and qualified small business ventures, as well as the credit for investments in rural small businesses in Oklahoma, would be repealed.

 

The governor also proposes revisions to the credit for the conversion of motor vehicles to clean burning fuel or investments in qualified electric motor vehicles.

 

In addition, a one-year moratorium on income tax credits for the 2010 tax year is proposed.

 

Decoupling from mortgage forgiveness provisions: As a part of the federal American Recovery and Reinvestment Act, forgiven mortgage debt under certain temporary tax provisions is excluded from taxable income for federal income tax purposes. A proposal would, for Oklahoma income tax purposes, consider that debt forgiveness amount to be taxable income, thereby decoupling from the federal tax provisions.

 
Due and Delinquent Dates for Franchise Tax Returns

 

Under current law, a franchise tax return must be remitted on July 1 or the last day of the income tax year of the taxpayer. The return is delinquent if not filed by September 1 or the 15th day of the fourth month following the end of the income tax year. The governor proposes to change those dates so that returns and payments from taxpayers paying the maximum tax amount would be captured in June, thereby creating a one-time increase in franchise tax collections for the 2011 fiscal year.

 
Sales and Use Tax Proposals

 

Sales and use tax-related proposals for fiscal year 2011, as outlined in the governor's budget, include the following:

 

-- to equalize the vendor discount at 1% for all vendors and cap the per-vendor maximum monthly compensation at $2,500 per month (currently, the monthly cap is $3,300 per month and the vendor discount is given at rates of 1.25% and 2.25%);

 

-- to impose sales tax on sales of items delivered electronically that would be subject to sales tax if delivered in a tangible form;

 

-- to require vendors that remit between $1,000 and $2,500 per month to remit sales tax on the 20th of the month for sales made during the 1st through the 15th instead of for sales made during the previous month;

 

-- to require liquor and wine wholesalers to remit sales tax on the 20th of each month for sales during the 1st through the 15th instead of remitting the tax on the 10th of the month for sales made during the previous month;

 

-- to require beer wholesalers that remit sales tax on 10th of the month for sales during the previous month in the amount of $2.3 million to remit tax on the 20th of the month for sales made during the 1st through the 15th;

 

-- to implement a compliance initiative to allow the Oklahoma Tax Commission to pursue sales tax collections from out-of-state businesses without a presence in Oklahoma that are not collecting sales tax on Internet, phone, and mail order sales made to Oklahoma; and

 

-- the adoption by the commission of the Multistate Tax Commission's model sales tax statutes requiring Internet accommodations intermediaries that book accommodations on a nonexclusive basis to collect sales tax on the entire retail price (including the margin).

 
Proposed Repeal of Motor Fuel "Eligible Purchaser" Discount

 

Since a motor fuel distributor no longer has any tax remitting responsibility, the current 1.6% discount for a gasoline distributor and the 1.9% discount for a diesel distributor, granted for a timely tax payment, would be repealed under the proposed budget.

 
Proposed Smokeless Tobacco and Little Cigar Tax Equalization

 

The governor also proposes converting the current tobacco products tax on moist smokeless tobacco from a value-based tax to a weight-based tax, so as to equalize the rate of taxation among similar tobacco products.

 

Under the budgetary proposals, a product falling within the "little cigar" statutory category would be taxed at the same tax rate as a cigarette, thus conforming Oklahoma law to the federal provisions that became effective April 1, 2009.

 
Proposed Increase to the Cost of Vending Machine Decals

 

Finally, under the proposed budget, the owner of a vending machine would have to purchase an annual decal at a cost of $150 per year. The current cost is $50 per year.

FY-2011 Executive Budget, Oklahoma Gov. Brad Henry, February 1, 2010

 

Rhode Island --Multiple Taxes: Proposed Budget Includes No Broad-Based Tax Increases, Creation of Small Business Tax Credit

 

Rhode Island Gov. Donald L. Carcieri has proposed a fiscal year 2011 budget that, among other proposals, reflects no increases in broad-based taxes, reduces the corporate/franchise minimum tax from $500 to $250, and creates a small business tax credit.

 

The small business jobs growth tax credit would allow certain businesses with between five and 100 employees in Rhode Island to receive a tax credit equal to $2,000 per new full-time employee. Eligibility for the tax credit would be dependent on several variables, including if the new employee hired had collected unemployment, received certain temporary assistance payments to needy families, or graduated from certain educational institutions in the past 24 months. The tax credit would be in effect from July 1, 2010, to December 31, 2011, and would require that the qualifying small business retain the newly hired employee for 18 consecutive months and have total employment after 18 months that is greater than the company's total employment prior to qualifying for the tax credit.

 
Elimination of Tax Credits

 

Additionally, the proposed budget would eliminate the motion picture production company tax credit and the enterprise zone wage tax credit.

 
Motor Vehicle Fees and Excise Tax Reimbursement

 

The governor proposes an increase in various motor vehicle fees, including the motor vehicle dealer license fee and motor vehicle manufacturer/distributor license fee. The proposal also would suspend payments to municipalities for reimbursement of the state exemption on the motor vehicle excise tax and provides a procedure by which municipalities may choose to levy a supplemental tax to recover the revenues lost as a result of the suspended state payments.

 
Hospital Licensing Fees

 

Under the proposal, the hospital licensing fee would be reinstated for one year using the current rate of assessment of 5.237%. [Note: The hospital licensing fee is imposed on the net patient services revenue of every hospital for the hospital's first fiscal year ending on or after January 1, 2008.]

Executive Summary Fiscal Year 2011 and Press Release, Rhode Island Gov. Donald L. Carcieri, February 2, 2010

 

West Virginia --Corporate Income, Franchise Taxes: Out of State Holding Company Taxable; Nexus Existed

 

A Nebraska corporation who licensed trademarks and trade names to others, including affiliated companies, who then sold trademarked and trade-named products to customers in West Virginia was subject to West Virginia corporate net income and business franchise tax. The Nebraska corporation met the requisite minimum contacts with West Virginia to satisfy the Due Process Clause of the U.S. Constitution since it availed itself of the economic forum of West Virginia when it licensed its trademarks and trade names to third parties who manufactured goods bearing those trademarks and trade names and then sold the goods in West Virginia. The Due Process Clause was further satisfied since the Nebraska corporation received benefits from West Virginia that were rationally related to the activity taxed in the form of royalties from sales made by its licensees in West Virginia.

 

The tax also did not violate the Commerce Clause of the U.S. Constitution because the "substantial economic presence test" was met when products bearing the Nebraska corporation's trademarks and trade names were systematically sold by the licensee in many retail grocery stores in West Virginia. Further, the taxes collected were fairly apportioned, did not discriminate against the Nebraska corporation, and were fairly related to the benefits provided by West Virginia.

Decision Nos. S 06-544N & 06-545FN, West Virginia Office of Tax Appeals, January 6, 2010, ¶400-711

 

Other References:

 

Explanations at ¶10-075

 

Explanations at ¶10-212


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