Alternatives to the deductibility of a charitable contribution for a qualified conservation easement under section 170(F)(3)(A)

Article Abstract:

An advantageous tax plan for developers other than charitable contributions is qualified conservation easement contributions under IRC section 170(F)(3)(A). This plan eliminates any duty to pay property taxes or special assessments and removes all potential tort liability as well as its tax benefits. However, developers are unable to benefit from many of the tax planning alternatives such as tax free property exchanges because properties purchased with the intent to sell are excluded and so capitalizing and expensing and tax consequences of selling the property must be considered.

Methods, Donations, Tax planning, Income tax

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Final section 482 transfer pricing regulation

Article Abstract:

The transfer pricing final regulations under IRC section 482 released by the IRS in 1994 are an improvement over temporary and proposed regulations, but practitioners should note that the regulations apply to both international and purely domestic transactions between all types of affiliated entities. The regulations apply arm's-length standards based on comparable, not identical, transactions. The regulations establish the best method rule for valuation and set forth several methods that are applicable to specific types of transactions.

Laws, regulations and rules, Transfer pricing, Related party transactions

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Muck and brass

Article Abstract:

The United Kingdom government passed its Finance Act in May 2001 and included provisions to helsp regeneration. Unwittingly these provisions will also provide developers of contaminated land with tax concessions.

United Kingdom, Usage, Tax deductions

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