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New 2004 Tax Legislation

Bankruptcy Legislation
> House Clears Bankruptcy Reform With Many Tax-Related Provisions

Contributions for Tsunami Victims (P.L. 109-1)
> Act Language: P.L. 109-1: Tax Benefits for Charitable Cash Contributions for Tsunami Victims (PDF)
> Client Letter: Overview of the Act

American Jobs Creation Act of 2004 (P.L. 108-357)

Analysis
> Tax Management Educational Institute Roundtable on New Nonqualified Deferred Compensation Rules under §409A (Including IRS Notice 2005-1) (Selected Article from Weekly Report)
> Leading Practitioner Commentary on the International Tax Provisions of the American Jobs Creation Act of 2004 (From a Special Supplement of the Tax Management Memorandum)
> The Tax Shelter Rules Come Full Circle: An Analysis of the Tax Shelter Provisions in the American Jobs Creation Act of 2004, by Mark Ely, Joan Rood, Harve Lewis (Selected Article from Weekly Report)
> Tax Management Educational Institute Roundtable on New §409A--Nonqualified Deferred Compensation Plans (Selected Article from Weekly Report)
> Assembling the Pieces of the Domestic Manufacturers' Deduction, by James L. Atkinson, Esq. (Selected Article from Weekly Report)

News and Explanation
> BNA Tax Management Summary

Tables, Charts and Lists
> Click here for Publication 600: Optional State Sales Tax Tables for 2004 (PDF)

Insights and Commentary
> The Trouble With New Section 470, by James J. Tobin, Esq...July 2005
> 457(f) Plans Need Review, or Participants May Pay High Price, by Brenda Berg, Esq...April 2005
> The Comings and Goings of Taxation, by Edward Tanenbaum, Esq...April 2005
> New §7874 Anti-Inversion Provision Has Broad Reach, by Jasper L. Cummings, Esq., and Kevin Rowe, Esq...April 2005
> Department of Treasury Issues Proposed Regulations on the Tax Treatment of Supplemental Wages, by Heather Heath Ryan, Esq. and Mary K. Samsa, Esq...March 2005
> Impact of AJCA of 2004 on the Prospects for Further International Tax Reform, by Philip D. Morrison, Esq...February 2005
> Repeal of Subpart F Shipping Income Provision Has Broad Reach, by Jerome B. Libin, Esq...February 2005
> The Death of the Discount Stock Option, by Andrew Rudolph, Esq. and David Kaplan, Esq...January 2005
> Anti-Inversion Legislation May Prevent Foreign IPOs, by Kenneth J. Krupsky, Esq...January 2005
> American Jobs Creation Act Addresses Exchanges of Partnership Debt for Equity But Creates Ambiguity Regarding Prior Law, by Donald B. Reynolds, Jr., Esq...January 2005
> Section 965: Technical Corrections Bill, by Lowell D. Yoder, Esq...January 2005
> IRS Issues Initial Guidance Under Section 409A of the Internal Revenue Code, by John E. McGrady, III, Esq...January 2005
> New Legislation Terminates IRS Interest Suspension for Reportable and Listed Transactions, by Barbara T. Kaplan, Esq., and Jessica M. Westbrook, Esq...December 2004
> One-Time Dividends Received Deduction for Extraordinary Dividends: Issues in Planning for Jointly-Owned CFCs, by David R. Tillinghast, Esq...December 2004
> Tax Shelter Reporting Rules Now Carry a Heavy Price Tag for Noncompliance, by Annette M. Ahlers, Esq...November 2004
> New §6043A--Additional Administrative Burdens Required for Reporting of a Taxable Merger or Acquisition, by Annette M. Ahlers, Esq...November 2004
> Deduction Relating to Income Attributable to Domestic Production Activities, by Todd B. Reinstein, Esq., CPA...November 2004
> More Favorable Depreciation Treatment Afforded Leasehold Improvements Under American Jobs Creation Act of 2004, by Donald B. Reynolds, Jr., Esq...November 2004
> American Jobs Creation Act of 2004 Limits The Deductibility of Entertainment Expenses, With a Focus on Private Aircraft Expenses, by H. Grace Kim, Esq...November 2004
> Proposed Law Would Create New Era for Deferred Compensation, by Louis R. Richey, JD, and Richard E. Magner...October 2004
> New Section 965 Contains Traps for the Unwary, by Philip D. Morrison, Esq...October 2004

Client Letters
> 2004 Year-End Tax Planning for Individuals (includes planning issues created by the American Jobs Creation Act)
> Overview of the Act
> Changes in Treatment of Nonqualified Deferred Compensation Plans
> Charitable Contribution Provisions
> Repeal of the Extraterritorial Income Exclusion and the New Deduction for Qualified Production Activities

Primary Sources
> Notice 2005-14: Guidance on Section 199--Income Attributable to Domestic Production Activities (DOC)
> Fact Sheet: Guidance on Section 199 – Income Attributable to Manufacturing Activities (PDF)
> Notice 2005-1: Guidance Under § 409A of the Internal Revenue Code (PDF)
> Conference Report (includes Act Language) (PDF)
> Revenue and Effective Date Table (PDF)

Working Families Tax Relief Act of 2004 (P.L. 108-311)

News and Explanation
> BNA Tax Management Summary

Insights and Commentary
> Changes to the Internal Revenue Code's Definition of Dependent, by Edward I. Leeds, Esq. and Kristin K. McCarthy, Esq...March 2005
> Working Families Tax Relief Act of 2004 Extends the Deduction for Brownfield Expenses, by Donald B. Reynolds, Jr., Esq.

Client Letters
> Overview of the Act
> Uniform Definition of Child

Primary Sources
> Act Language (PDF)
> Statement of Managers for the Conference Report (PDF)
> Revenue and Effective Date Table (PDF)