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October 6,  2008

Federal Headlines


President Signs Financial Rescue Bill Containing AMT Relief, Tax Extenders and Energy Incentives

 

President Bush on October 3 signed a massive financial rescue package, the Emergency Economic Stabilization Act of 2008, Energy Improvement and Extension Act of 2008 and Tax Extenders and Alternative Minimum Tax Relief Act of 2008 (HR 1424) that authorizes the Secretary of the Treasury to establish a troubled assets relief program, provides a temporary alternative minimum tax (AMT) fix, extension of expiring tax provisions and energy tax incentives. The president signed the Wall Street rescue package only a few hours after it was passed in the House by a vote of 263 to 171. The Senate passed the measure on October 1 (TAXDAY, 2008/10/02, C.1).

 

The legislation grants the Treasury Department up to $700 billion to purchase assets from troubled financial companies in an effort to jump-start the flow of credit in the economy. However, the bill inserts greater congressional oversight over the flow of funds to the Treasury and includes greater protections for taxpayers. It also lifts the ceiling on the Federal Deposit Insurance Corporation's (FDIC) guarantee on bank deposits from $100,000 to $250,000. Other provisions of the bill limit the so-called "golden parachutes" that executives of failed institutions can receive if their firms take advantage of the Treasury bailout plan.

 

The FDIC provision appeared to be a crucial component for garnering additional House votes after the chamber on September 29 rejected the Emergency Economic Stabilization Bill of 2008 (HR 3997) by a vote of 228 to 205 (TAXDAY, 2008/09/30, C.1). House Republicans voting against that measure totaled 133, with 95 Democrats joining them. The defeat of the original version was fueled by Republicans' anger over what they perceived as the overly-partisan nature of the bailout debate.

 

The president, shortly after House passage of the rescue bill, commended congressional leaders for working together in a timely manner to pass the measure. "By coming together on this legislation, we have acted boldly to help prevent the crisis on Wall Street from becoming a crisis in communities across our country," Bush said in the Rose Garden. "We have shown the world that the United States of America will stabilize our financial markets and maintain a leading role in the global economy," Bush stated.

 

Treasury Secretary Henry M. Paulson said the government will move rapidly, but also methodically, to implement the new authorities. "Transparency throughout this process will be important, and I look forward to providing regular updates as we move ahead to implement this strategy," he said.

 

Paulson said the broad authorities in the legislation, combined with existing regulatory authorities and resources, "give us the ability to protect and recapitalize our financial system as we work through the stresses in our credit markets."

 

From a tax administration perspective, IRS Commissioner Douglas H. Shulman praised Congress for passing the AMT patch and tax extenders in enough time for the IRS to handle the changes on its tax forms and computer systems. In 2007, AMT and extenders legislation retroactive to the start of 2007 was not enacted under December 26, 2007, putting the IRS behind in accepting and processes 2007 tax forms for many weeks into the 2008 filing season. In a written statement immediately after passage of the legislation, Shulman commented, "Timely passage of the AMT and extenders provisions is a great outcome for the nation's taxpayers. This gives the Internal Revenue Service enough time to prepare for the upcoming tax season."

 

House Speaker Nancy Pelosi, D-Calif., called the measure a "much improved" version of the earlier draft. "Our eye now is to the future, to shine the bright light of accountability on what is happening in our financial markets so that it doesn't happen again." House Minority Leader John Boehner, R-Ohio, described the bill as an "imperfect product," but stressed that Congress had a responsibility to act.

 

Despite repeated promises not to pass a tax extenders bill that was not fully offset by revenue increases or spending cuts, House Ways and Means Committee Chairman Charles B. Rangel, D-N.Y., cast his vote for the bailout bill. The bailout measure included the entire text of HR 6049, as amended by the Senate on September 23 (TAXDAY, 2008/09/24, C.1). Rangel and House Majority Leader Steny L. Hoyer, D-Md., said that they supported the clean energy tax incentives, AMT relief, extensions of expiring business and family tax cuts, disaster relief, mental health parity and other provisions in the bill, even though they did not meet the House pay-as-you-go budget rules.

 

The combined cost for all the tax measures, energy, AMT, extenders and other provisions, is $150.496 billion, and the offsets in the package total $43.504 billion. Hoyer said that the addition of the tax provisions, combined with the stock market losses and state financial problems, prompted members to switch their votes to approve the bill. According to Hoyer's office, the 111th Congress will convene on January 6, 2009. However, several Democratic lawmakers said they would return to Capitol Hill in mid-November for party organization meetings.

 

The American Bankers Association (ABA) said the legislation would provide "the financial backstop needed to unfreeze the financial markets and provide for greater transparency and accountability for firms that participate in the program."

 

By Sarah Borchersen-Keto, Stephen K. Cooper, Paula Cruickshank and George Jones, CCH News Staff

SFC Release: Congress Approves Financial Rescue Plan with Baucus Protections for Taxpayers, Tax Relief to Promote Jobs, Energy, Families

SFC Release: Grassley Praises Signing of Bill to Shield Taxpayers from AMT, Offer Tax Relief for Iowa Disaster Recovery, Continue Tax Incentives for Wind Energy, Tax Relief for College Tuition

Ways and Means Release: Rangel Statement on Financial Rescue Bill

SAP on HR 1424 --Emergency Economic Stabilization Act of 2008, Energy Improvement and Extension Act of 2008, and Tax Extenders and Alternative Minimum Tax Relief Act of 2008

Statement by the President on the Emergency Economic Stabilization Act of 2008

White House Fact Sheet on Safeguarding the Financial Future of American Workers and Families

Treasury Department News Release, TDNR HP-1175

 

CCH Weekly Report from Washington, D.C.

 

While the tax provisions of the recently enacted Emergency Economic Stabilization Act of 2008 (HR 1424) may have taken most of the spotlight during the week of September 29, the IRS and Treasury continued releasing guidance on other important tax issues. These topics included the financial markets, exempt organizations compliance, nonqualified deferred compensation and disaster relief.

 

Financial Markets. The Treasury is making market-related guidance a priority in light of the present financial crisis. Newly released guidance toward that effort covered several areas:

 

Banks and Code Sec. 382(h). For purposes of Code Sec. 382(h), the IRS has assured financial institutions that any deduction properly allowed after an ownership change of a banking corporation with respect to losses on loans or bad debts, or reasonable additions to its bad debt reserve, shall not be treated as a built-in loss or a deduction attributable to periods before the change date (Notice 2008-83).

 

Government ownership and Code Sec. 382. The Treasury and the IRS have also announced that they will issue regulations providing that the closing date on which the U.S. government directly or indirectly owns a more-than-50-percent interest in a loss corporation will not be considered a testing date for purposes of Code Sec. 382 (Notice 2008-84).

 

Bankruptcy default and Code Sec. 1058(a). The IRS has also provided guidance regarding the application of Code Sec. 1058(a) to situations involving securities loan agreements where the borrower subsequently defaults as a result of its bankruptcy and the lender uses collateral provided pursuant to the agreement to purchase identical securities (Rev. Proc. 2008-63). Subject to several conditions, the purchase of the identical securities will not result in the loss of tax-free treatment under Code Sec. 1058(a) for the lender.

 

Bail-out contributions and Code Sec. 382. The IRS announced it would issue regulations under Code Sec. 382(l)(1), to provide that a capital contribution is not part of a plan to purchase a corporation with net operating loss (NOL) carryforwards and use those carryforwards to offset the purchaser's other income solely because it was made within the two year period before the change of ownership (Notice 2008-78).

 

Exempt Organizations Compliance. The IRS is sending compliance questionnaires focused on unrelated business income, endowments, and executive compensation practices to approximately 400 U.S. colleges and universities (IR-2008-112). The questionnaires are part of the IRS's effort to study the tax-exempt community.

 

Ronald Schultz, IRS senior technical advisor, Tax Exempt and Government Entities Division (TE/GE), warned tax-exempt organizations and their advisors on October 1 that major changes to compensation reporting in the new 2008 Form 990 require answers to a whole new set of questions, as well as a fresh understanding of how to translate those answers into compliance.

 

The IRS has issued guidance amending and supplementing Notice 2008-41, I.R.B. 2008-15, 742, regarding reissuance standards for tax-exempt bonds (Notice 2008-88). The guidance expands the circumstances and time periods during which a state or local government may repurchase bonds it issued without resulting in a reissuance or retirement of such bonds under relevant tax code provisions.

 

Nonqualified Deferred Compensation Although the IRS will continue not to issue advance rulings or determination letters on the income tax consequences of establishing, operating, or participating in a Code Sec. 409A nonqualified deferred compensation plan, the agency has announced that it may issue rulings on the application of certain other tax provisions to participating taxpayers (Rev. Proc. 2008-61).

 

Mortality Tables The IRS has updated the static mortality tables to be used under Code Secs. 417 and 430 for purposes of calculating the funding target and other items for valuation for defined benefit plans (Notice 2008-85).

 

The IRS has provided guidance on the requirements of defined benefit plan sponsors wishing to use substitute mortality tables in determining the plan's minimum funding requirements, as allowed under Code Sec. 430(h)(3)(C) (Rev. Proc. 2008-62). This is an update of Rev. Proc. 2007-37, I.R.B. 2007-25, 1433, which was based on proposed regulations.

 

Disaster relief. The IRS recently published a list of the counties and parishes in the United States that have suffered exceptional, severe or extreme drought during the 12 months ending August 31, 2007, sufficient to extend the livestock replacement period (Notice 2008-86). As authorized in Code Sec. 1033(e)(2)(B) and implemented in Notice 2006-82, I.R.B. 2006-39, 529, an extended replacement period is available for livestock sold on account of extreme weather conditions until the end of the first taxable year ending after the first drought-free year.

 

Korb Departing. IRS Chief Counsel Donald L. Korb has announced his intention to leave his current position, effective January 19, 2009. Korb stated on October 2 that he was announcing his resignation at this time to give notice to "those many qualified individuals" who may wish to apply for the position as his successor. Korb will have served in the position of IRS Chief Counsel for four years and nine months at the time of his departure.

 

By Torie Cole, CCH News Staff


State Headlines


District of Columbia --Corporate, Personal Income Taxes: U.S. Supreme Court Asked to Determine Scope of Federal Jurisdiction in Tax Challenge

 

Taxpayers have asked the U.S. Supreme Court whether the federal courts lack jurisdiction over the taxpayers' action challenging the District of Columbia unincorporated business tax. The taxpayers are nonresidents of the District who paid unincorporated business tax on their personal incomes as a result of their membership in real estate limited liability companies in the District. They filed an action in the U.S. District Court for the District of Columbia seeking a declaration that the tax violates federal law and the U.S. Constitution.

 

The federal court dismissed the action, holding that challenges to District tax assessments, including the imposition of tax, are by federal statute not within federal jurisdiction because Congress granted exclusive jurisdiction over such cases to the District's courts. The court added that this result parallels the mandate of the federal Tax Injunction Act, 28 U.S.C. §1341. This result is not affected by the fact that the District's courts already have rejected an identical challenge in Bender, 906 A.2d 277 (D.C. 2006), cert. denied, 127 S. Ct. 1356 (2007). The U.S. Court of Appeals for the District of Columbia Circuit summarily affirmed the lower court.

 

The taxpayers ask the high court whether the exclusive jurisdiction of the District's courts extends beyond challenges to the "assessment" of a tax to challenges to the imposition of a tax, where a tax refund is not sought.

Fernebok v. District of Columbia, U.S. Supreme Court, Dkt. 08-391, petition for certiorari filed September 22, 2008.

 


Kentucky --Sales and Use Tax: Local Ordinances Inapplicable to Online Travel Companies

 

Local ordinances that impose a Kentucky transient room tax on the rental of rooms were inapplicable to Internet businesses (i.e., online travel companies) that do not have ownership or physical control of the rooms they offer for rent. The ordinances impose a transient room tax on a percentage of the rent "...for every occupancy of a suite, room or rooms, charged by all persons, companies, corporations, or other like or similar persons, groups, or organizations, doing business as motor courts, motels, hotels, inns or like or similar accommodations businesses." A county alleged that the online travel companies (OTCs) negotiate with hotels for a discounted or wholesale price for rooms that they then purchase and resell to guests at a marked up or retail rate. The companies pay the transient room tax on the wholesale price but keep the difference between that amount and the amount of tax the guests pay on the retail price. The county claimed the travel companies should pay the tax on the higher retail price. The court found that the OTCs do not meet the definition of "like or similar accommodations businesses." Internet businesses that do not have ownership or physical control of the rooms they offer for rent are not like or similar to motor courts, motels, hotels, or inns. As such, the local taxing ordinances were inapplicable to the OTCs.

Louisville/Jefferson County Metro Government v. Hotels.com, LP, U.S. District Court, Western District of Kentucky, No. 3:06-CV-480-R, September 26, 2008,

¶202-848.

 

Other References:

 

Explanations at ¶60-480 .


Michigan --Corporate Income Tax: Bill Would Repeal MBT Surcharge

 

The Michigan Senate passed legislation that would, if enacted, phase out the surcharge on the Michigan business tax and effectively repeal it for tax years ending after 2010. Currently, the surcharge will sunset after 2016, provided that the Michigan personal income growth exceeds 0% in either 2014, 2015, or 2016. For all taxpayers, other than financial institutions, the surcharge would be:

 

-- 21.99% for tax years ending after 2007 and before 2009;

 

-- 14.66% for tax years ending after 2008 and before 2010; and

 

-- 7.33% for tax years ending after 2009 and before 2011.

Currently, the surcharge for such taxpayers is 21.99%.

 

For financial institutions taxpayers, subject to the franchise tax, the surcharge would be:

 

-- 27.7% for tax years ending after 2007 and before 2009 (no change);

 

-- 18.47% for tax years ending after 2008 and before 2010 (currently, 23.4%); and

 

-- 9.24% for tax years ending after 2009 and before 2011 (currently, 23.4%).

 

Subscribers to CCH Tax Research NetWork can view the bill in its entirety.

S.B. 1242, as passed by the Michigan Senate, October 2, 2008.

 

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