Of course, the company, in preparing for its audit, will need to document its deferred tax computation for various taxing
jurisdictions - how it arrived at its determination of the marginal tax rate, for example, and the necessity for and the amount of any valuation allowance.
or Canada are considered to be contributions to a qualifying organization in the taxing
country; see Treaty Article XXIX B.
Even Treasury Secretary Andrew Mellon, that patron saint of supply siders, acknowledged that, "The fairness of taxing
more lightly income from wages, salaries, than from investment is beyond question,"
The result of all this is to roughly triple current federal revenue from taxing
businesses, while halving individual income tax revenue.
Most states have confronted the software taxation problem by taxing
canned or off-the-shelf software but exempting custom-made software as a service sale.
SB 2310, Laws 2005: (1) more broadly defines unitary group for purposes of determining which entities must be included in the financial organization's unitary group; (2) provides that if any member has nexus with Tennessee, the Tennessee receipts of all members (even those without nexus) must be included in the numerator of the receipts factor; and (3) increases the percentage of receipts attributable to the state by requiring a portion of the receipts that currently are not included in the numerator to be included by providing that any other receipts not specifically attributed to Tennessee or to another taxing
jurisdiction must be attributed to Tennessee in the same proportion that the enumerated receipts are attributed to Tennessee.
During the past three decades, this Court has invoked the Commerce Clause to invalidate state taxing
schemes that unreasonably burdened interstate commerce by discriminating against out-of-state taxpayers.
And in any case, even with Clinton's world-record $300-billion tax increase, the United States will still be a less taxing
nation than Sweden, Denmark, and France.
Is the tax applied to an activity with a substantial nexus with the taxing
Based on our members' experience in managing federal, state, and foreign tax audits and resolving disputes, TEI disagrees with the proposed Interpretation's presumption that a taxing
authority will examine all tax positions, assert a claim, and disallow every tax position that is not supported at a "probable" level of confidence.