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October 7,  2008

Federal Headlines


IRS Relaxes Controlled Foreign Corporation Short-Term Debt Exception for Obligations of U.S Persons (Notice 2008-91)

 

In response to the liquidity crisis, which has made it difficult for taxpayers to fund their operations, the IRS has temporarily relaxed the standards set forth in Notice 88-108, 1988-2 CB 445, for the exclusion of certain obligations from the definition of U.S. property on which U.S. shareholders of a controlled foreign corporation (CFC) are taxed.

 

Notice 88-108 excludes from the definition of the term "obligation" (Code Sec. 956(c)(1)(C)) an obligation that would constitute an investment in U.S. property if it is held at the end of a CFC's tax year, so long as the obligation is collected within 30 days from the time it is incurred. This exclusion does not apply, however, if the CFC holds for 60 or more calendar days during such tax year obligations that, without regard to the 30-day rule, would constitute an investment in United States property if it is held at the end of the CFC's tax year.

 

Under the new rules, a CFC may choose to exclude from the definition of the term "obligation" an obligation held by the CFC that would constitute an investment in United States property provided the obligation is collected within 60 days from the time it is incurred. This exclusion does not apply if the CFC holds for 180 or more calendar days during such tax year obligations that, without regard to the 60-day rule, would constitute an investment in United States property.

 

The latest rules do not otherwise affect the application of Notice 88-108. A CFC may apply the relaxed rules or the rules contained in Notice 88-108, but not both.

 

The new rules apply for the first two tax years of a foreign corporation ending after October 3, 2008.

Notice 2008-91, 2008FED ¶46,603

Other References:

 

Code Sec. 956

 

CCH Reference - 2008FED ¶28,576.023

 

CCH Reference - 2008FED ¶28,576.35

 

Tax Research Consultant

 

CCH Reference - TRC INTLOUT: 9,256.15


Partners Holding Different Interests Could Make Different Partnership Elections (JT USA LP, TC)

 

Partners holding various interests in a partnership, both as direct and indirect partners, were allowed to make separate elections for each interest. The IRS had issued a notice of final partnership adjustment (FPAA) to the partners without providing a proper notice under Code Sec. 6223(a). The IRS sent out an FPAA just in time to beat the statute of limitations, but did not provide notice that audit proceedings had begun; thus the partners had the right to opt out of partnership-level proceedings. Further, the partners' elections to opt out of the partnership-level proceeding only in their capacity as indirect partners were valid. Their elections to "opt in" in their capacity as direct partners had no effect because the default rule dictated the same result. Under Code Sec. 6223(e)(3), a partner is bound by the TEFRA proceedings unless a proper election is made to opt out. The elections in were just a result of an incorrect letter sent out with the FPAA and had no effect one way or the other.

JT USA LP, 131 TC No. 7, Dec. 57,550

Other References:

 

Code Sec. 6223

 

CCH Reference - 2008FED ¶37,639.40

 

Tax Research Consultant

 

CCH Reference - TRC PART: 60,150


State Headlines


All States --Multiple Taxes: U.S. Supreme Court Rejects Several State Tax Petitions on Opening Day

 

On the first day of its new session, the U.S. Supreme Court denied several requests for review of state and local tax matters that had been pending before it. The rejected petitions are summarized below.

 

-- California: A taxpayer had asked the Court whether the procedures followed in a California property tax sale met the due process standards of the U.S. Constitution. The California Court of Appeal held that the county's efforts to provide notice of the pending sale were constitutionally adequate.  Indyway Investment v. Opri, Dkt. 07-1479, petition for certiorari denied October 6, 2008. A separate petition arising from the same transaction, raising similar issues, and filed by the same taxpayer is still pending with the Court.

 

-- Michigan: A purchaser at a Michigan property tax foreclosure sale had asked the Court whether its due process rights were violated by the retroactive application of a rule that resulted in the nullification of the sale. After a judgment of foreclosure was entered and the tax sale to the purchaser occurred, the county treasurer discovered that the property belonged to a local government entity. Michigan law prohibits the foreclosure sale of publicly owned property and, consequently, the treasurer sought to nullify the sale. The Michigan Supreme Court agreed that the sale must be set aside based on the relevant statute. The purchaser argued unsuccessfully for reconsideration on the basis that the rule implementing the statute had not been promulgated until after the judgment of foreclosure was entered. Michigan Financial Investments, LLC v. Detroit Building Authority, Dkt. 07-1605, petition for certiorari denied October 6, 2008.

 

-- Michigan: A developer of residential subdivisions had asked the Court to review a decision concluding that the developer should have paid the Michigan real estate transfer tax based on the value of certain lots, as improved by homes built on the lots. The Michigan Supreme Court held that the tax applies to recorded instruments and the only recorded instrument in this case was the deed. Therefore, because the value exchanged for the deed included both the cost of the lot and the home, that value was the proper measure for taxation.  Lake Forest Partners 2, Inc. v. Michigan Department of Treasury, Dkt. 08-109, petition for certiorari denied October 6, 2008.

 

-- Oklahoma: Members of the Oklahoma Tax Commission had asked the Court whether an action against them seeking to enjoin the state's assessment of personal income tax on tribal members may proceed in federal court. The Osage Nation filed an action in federal district court seeking to enjoin the assessment of tax on tribal members who are employed by the tribe and reside in Osage County, an area co-extensive with the tribe's historical reservation. The tribe also sought a declaratory judgment that its reservation, comprising all of Osage County, is Indian country. The state maintains that the reservation was incorporated into Oklahoma at the time of its statehood and that only a small fraction of the land within Osage County is Indian country. The state parties named in the suit, including the individual Commission members, moved to have the action dismissed on the grounds of state sovereign immunity. The district court refused to dismiss the action. On appeal, the U.S. Court of Appeals for the Tenth Circuit dismissed the action against the state and the Commission itself, but allowed the action to proceed against the individual Commission members. The Court of Appeals held that the action is permitted by the doctrine in Ex parte Young, 209 U.S. 123 (1908), because the relief sought is prospective in nature.  Kemp v. Osage Nation, Dkt. 07-1484, petition for certiorari denied October 6, 2008.

 

-- Washington: A member of a Native American tribe had asked the Court whether Washington cigarette tax laws apply to his shipments of cigarettes between reservations. The tribal member (and cigarette retailer) asserted that federal law preempts an agreement governing the taxation of cigarettes sold in Indian country entered into between the state and the tribe to which he belongs. The Washington Court of Appeals affirmed the dismissal of the individual's lawsuit challenging this agreement on the basis that the tribe, which asserted its sovereign immunity from suit, was an indispensable party.  Matheson v. Gregoire, Dkt. 08-23, petition for certiorari denied October 6, 2008.

 
Requests for Review Still Pending

 

At the present time, the Court has not granted any request for review of a pending state or local tax matter. The only such matter left over from its last term that the Court has not disposed of is the petition in Columbia Gas Transmission Corp. v. Levin, Tax Commissioner of Ohio, Dkt. 07-1554, petition for certiorari filed June 12, 2008.  In this case, a federally regulated interstate natural gas pipeline company has asked the Court whether it was a Commerce Clause violation for Ohio to tax the company's pipeline equipment at the higher personal property tax rate for interstate pipeline companies, rather than at the lower rate for functionally identical equipment used by local natural gas companies, even though the company also delivered natural gas to Ohio consumers. Ohio had waived its right to file a response, but the Court requested a response and gave the state until December 1, 2008, to do so. At some point after that date, the Court will announce whether it will agree to review the issue or not.

 

Other requests for review still awaiting disposition, which were filed over the summer after the Court's last term ended, include the following:

 

-- Alaska: An operator of oil tankers has asked the Court whether an Alaska city's personal property tax on large vessels docking at private facilities violates the U.S. Constitution.  Polar Tankers, Inc. v. Valdez, Dkt. 08-310, petition for certiorari filed September 8, 2008.

 

-- District of Columbia: Taxpayers have asked the Court whether the federal courts lack jurisdiction over the taxpayers' action challenging the District of Columbia unincorporated business tax.  Fernebok v. District of Columbia, Dkt. 08-391, petition for certiorari filed September 22, 2008.

 

-- New York: A corporation has asked the Court whether its due process rights to notice were violated in New York property tax lien foreclosure proceedings.  114 Tenth Avenue Assoc., Inc. v. NYCTL 1999-1 Trust, Dkt. 08-184, petition for certiorari filed August 12, 2008.

Order List, U.S. Supreme Court, October 6, 2008.

 

California --Personal Income Tax: 2008 Tax Rate Schedules, Exemption and Other Amounts Released

 

The California Franchise Tax Board (FTB) has released indexed 2008 California personal income tax rate schedules, return filing thresholds, standard deduction amounts, itemized deduction limitation amounts, personal exemption amounts, credit amounts, and alternative minimum tax exemption amounts.

 
Tax Rate Schedules

 

For 2008, the indexed personal income tax rates for single taxpayers and married taxpayers filing separately range from 1% of the first $7,168 (formerly, $6,827) of taxable income to 9.3% of taxable income over $47,055 (formerly, $44,814). For married taxpayers filing jointly and surviving spouses with a dependent child, the rates range from 1% of the first $14,336 (formerly, $13,654) of taxable income to 9.3% of taxable income over $94,110 (formerly, $89,628). For taxpayers filing as heads of households, the rates range from 1% of the first $14,345 (formerly, $13,662) of taxable income to 9.3% of taxable income over $64,050 (formerly, $61,000).

 
Return Filing Thresholds

 

For the 2008 taxable year, a single taxpayer or head of household taxpayer must file a return if the taxpayer's adjusted gross income (AGI) exceeds an amount ranging from $11,876 to $30,731 (formerly, $11,310 to $29,240), or if the taxpayer's gross income exceeds an amount ranging from $14,845 to $33,700 (formerly, $14,138 to $32,068). A surviving spouse taxpayer with dependents must file a return if the taxpayer's AGI exceeds an amount ranging from $22,176 to $30,731 (formerly, $21,110 to $29,240), or if the taxpayer's gross income exceeds an amount ranging from $25,145 to $33,700 (formerly, $23,938 to $32,068). The corresponding AGI and gross income thresholds requiring married couples to file a return range from $23,752 to $47,557 (formerly, $22,620 to $45,250), and from $29,690 to $53,495 (formerly, $28,276 to $50,906), respectively. The number of dependents and the taxpayer's age (under 65, or 65 or older) determine the filing threshold level that applies.

 
Standard Deduction

 

For 2008, the standard deduction increases to $3,692 (formerly, $3,516) for single taxpayers and married taxpayers filing separate returns, and to $7,384 (formerly, $7,032) for married taxpayers filing jointly, surviving spouses, and heads of households.

 
Itemized Deduction Limitation Amounts

 

The AGI thresholds that activate the reduction of California itemized deductions for 2008 are $163,187 (formerly, $155,416) for single taxpayers and married taxpayers filing separately, $326,379 (formerly, $310,837) for married taxpayers filing jointly and surviving spouses, and $244,785 (formerly, $233,129) for heads of households.

 
Personal Exemptions

 

Personal exemption amounts for 2008 increase to $99 (formerly, $94) for single taxpayers, married taxpayers filing separately, and heads of households, and to $198 (formerly, $188) for married taxpayers filing jointly and surviving spouses. The dependent exemption amount for 2008 increases to $309 (formerly, $294) for each dependent claimed.

 

The adjusted gross income (AGI) thresholds that activate the reduction of California personal exemption credits for 2008 are $163,187 (formerly, $155,416) for single taxpayers and married taxpayers filing separately, $326,379 (formerly, $310,837) for married taxpayers filing jointly and surviving spouses, and $244,785 (formerly, $233,129) for heads of households.

 
Credit Amounts

 

The joint custody head of household credit and dependent parent credit are indexed for 2008 to the lesser of $393 (formerly, $374) or 30% of net tax.

 

The qualified senior head of household credit is indexed for 2008 to 2% of taxable income of up to $63,831 (formerly, $60,791), up to a $1,203 (formerly, $1,146) maximum credit amount.

 

The maximum AGI amounts for the renter's credit are indexed for 2008 to $34,936 (formerly, $33,272) for single filers and $69,872 (formerly, $66,544) for joint filers.

 
Alternative Minimum Tax Exemption Amounts

 

The alternative minimum tax exemption amounts for 2008 are increased to $60,014 (formerly, $57,156) for single or unmarried taxpayers, $40,007 (formerly, $38,102) for married taxpayers filing separately and estates and trusts, and $80,017 (formerly, $76,207) for married taxpayers filing jointly and surviving spouses. Exemption phaseouts begin at the following alternative minimum taxable income levels for 2008: $225,050 (formerly, $214,333) for single or unmarried taxpayers, $150,031 (formerly, $142,887) for married taxpayers filing separately and estates and trusts, and $300,065 (formerly, $285,776) for married taxpayers filing jointly and surviving spouses.

 

Subscribers to CCH Tax Research NetWork can view the FTB release.

News Release, California Franchise Tax Board, October 3, 2008.

 


California --Miscellaneous Tax: Locally Mandated Health Expenditure Program Not Preempted by ERISA

 

San Francisco's ordinance requiring certain employers to either provide evidence of a requisite level of monetary expenditures toward their employees' health coverage or benefits or pay a specified dollar amount per employee to the city for purposes of funding its health assistance program (HAP) was not preempted by the federal Employee Retirement Security Act of 1974 (ERISA). In so ruling, the U.S. Ninth Circuit Court of Appeals noted that there is a presumption against a finding of federal preemption in cases involving an area such as health care, which is a field that has traditionally been governed by the states or local governments.

 

The court rejected the argument that the city-payment option created an ERISA plan. The payments required by employers were made to the city and did not involve the exercise of employer discretion as to how the benefits would be provided. Rather, the employer simply determined the amount that had to be paid based on the number of employees and the employees' hours worked in San Francisco and maintained records to substantiate the amount that had to be paid and what health care expenditures were actually made by the employer. These requirements did not arise to the level of activity to which ERISA was directed, which was to ensure that employers did not abuse their discretion in managing funds that were held in trust to provide specified employee benefits. Under the ordinance, the employers who elect the city-payment option did not promise any benefits to its employees. Such employers' obligations under the program ceased upon the payment to city. There was no guarantee that specified benefits would be provided to the employers' employees or that a particular group of intended beneficiaries would be included in HAP.

 

The court also rejected the argument raised by the U.S. Secretary of Labor in its amicus brief that the HAP was an ERISA plan itself and therefore was preempted by ERISA. The court found that HAP was a local government entitlement program available to low- and moderate-income residents, regardless of employment status. The fact that employees might pay a discounted enrollment fee because their employers participated in the city-payment option was not sufficient to make HAP a program, plan, or fund within the meaning of ERISA. More importantly the program was run by the city, not the employers.

 

Finally, the court rejected the argument that ERISA preempted the ordinance because the ordinance made an impermissible reference to ERISA plans. The ordinance did not require employers to adopt an ERISA plan or health plan. It did not require employers to provide specific types of coverage or benefits under ERISA plans. It only required employers to spend a requisite amount on health care, whether the expenditures were made through an ERISA plan or through the city-payment option. In addition, the ordinance did not impose any extra administrative or financial duties on employers that had existing ERISA plans. Finally, the ordinance was fully functional in the absence of any employer ERISA plan, and consequently it did not make an impermissible reference to ERISA plans.

Golden Gate Restaurant Association v. City and County of San Francisco, U.S. Court of Appeals for the Ninth Circuit, No. 07-17372, September 30, 2008,

¶404-770

 

Other References:

 

Explanations at ¶34-150


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