The mining dust settles on "income tax in the U.S. sense."

Article Abstract:

The US Tax Court ruled in Texasgulf, Inc. v. Commissioner that Ontario Mining Tax payments were creditable as income tax payments to a foreign taxing authority. The IRS had argued that some of the profit calculation methods available under the tax scheme were not income taxes. The Tax Court was receptive to industry-wide data provided by the taxpayer that demonstrated that the tax was an income tax in the US sense. Taxpayers in other industries should also consider the use of broad industry data to support foreign tax credit positions.

Public Finance Activities, Corporate Tax Reduction, Taxation, Cases, Corporate taxes, Ontario, Foreign tax credit, Mineral deposits, Mines and mineral resources, Mining

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Measuring discharge of indebtedness income from debt modification

Article Abstract:

Discharge of indebtedness income (DOD income) from debt modification is measured by the issue price of the new debt obligation except in the case of publicly traded debt instruments. Section 108(e)(11) defines when DOD income results from debt modification; Sections 1273 and 1274 cover determination of the issue price. Courts are divided on whether interest rate changes alone are considered modification of debt. Original issue discount regulations need to be considered when calculating DOD income.

Extinguishment of debts, Debt cancellation, Discount (Finance)

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Economic Growth and Tax Relief Reconciliation Act of 2001

Article Abstract:

The Economic Growth and Tax Relief Reconciliation Act of 2001 is discussed, including its income tax rate cuts, marriage penalty relief, child and other tax credits, and estate tax phase out,

United States, Evaluation, Tax law

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