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67 Taxes 1 (1989)

handle is hein.journals/taxtm67 and id is 1 raw text is: .7Iic TAX MAGAZINE This magazine is pub- lished to promote sound thought In economic, legal and accounting principles relating to all federal and state taxation. To this end it contains signed articles on tax subjects of current interest and re- ports by the OCH Editorial Staff on recent federal and state tax matters. The editorial policy is to allow frank discussion of tax issues. On this basis contributions are Invited. Responsibility Is not as- sumed for the contents of the articles or for the opinions expressed therein. Editor Gene 0. SJostrand Washington Editor James R. McNelIs Bus ss Manager James A. Merchant Circudation Manager Donald B. Izban 'AXES--The Tax Maia- sine (ISSN 0040.1A1) Is published monthly by Commerce Clearing House, Inc., 4025 W. Peterson Ave., Chicago, IL 60646. Second-class postage paid at Chicago, Illinois. POST NASTUE: SEND AD- DRESS CHANGES TO TAXES-The Twa Maga- sift, 4025 W. PETERSON AVE., CHICAGO, ILW- NOIS 60646. Subbcription te: 50, 1 year: $5 single copy. January. 1W. VOL 60. No. 1. Change of address should be received at least 30 days before the date of the Issue with which it is to take effect. S1961. Commerce Clear- ing House, Inc. All rlight reserved. Printed in U.S.A. JANUARY 1989 * VOL. 67 NO. 1 Tax Notes .................................................... 2 What the Value-Added Tax Is All About ............................ 3 Peter Chiu and Joel G. Siegel examine the value-added tax as it exists in the United Kingdom and discuss aspects of the tax that may pose prob- lems for tax professionals if the tax is enacted in the United States. The Last Roundup of the AIlU: Get Along, You Nonreformers ........ 14 The latest appearance in these pages of the American Institute for Legal Jurimetrics, whose active members, Walter J. Blum and Willard H. Pedrick, consider recent and future efforts at tax reform. Securities Partnerships: Passive Loss Rules and Other Limitations ..... 18 The application of the passive loss rules and other limitations to securities partnerships is focused on by Lawrence M. Noe, William Taggart, Jr., Robert Glassman and Dina C. Stern. State Taxes ................................................. 47 The Deemed Paid Foreign Tax Credit: Earnings and Profits Utilization and Translation Clarifications . .............................. 48 B. Anthony Billings and Gary A. McGill analyze the effect of recently issued Internal Revenue Service notices on the foreign tax credit provisions. In Washington ............................................... 60 The 100 Percent Penalty: Avoidance and Mitigation ................. 61 How a small to medium-sized employer may become liable for the 100 per- cent penalty for failing to remit withholding payments, and steps the practitioner may take both to avoid such a penalty and to mitigate its effects are discussed by Stephen P. Kauffman. Taxation of Damage Awards: The Tax Court's Shifting Standard ...... 71 David G. Jaeger examines recent Tax Court rulings on the taxability of damage awards. Tax Meetings ................................................ 79

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