Vol. 23 No. 2, February 1992
Index
- IRS small pension plan audit (and amnesty) program; March 31 deadline nears for program that resolves cases quickly and reduces taxpayer liability.
- Proliferating gains under Sec. 357(c); Letter Ruling 9032006 represents a literal reading of this section, but it is economically unsound.
- Tax trap on deceased shareholder's redemption.
- Bona fide resident status for the earned income exclusion is now available to foreign nationals under certain U.S. treaties.
- Thrift NOL carrybacks may be in jeopardy.
- U.S.-Canadian cross-border retirement planning.
- IRS targets retirement plan funds.
- New procedure for IRS informal technical advice.
- Tax court limits availability of AMT tax benefit rule.
- Tax consequences of debt modifications.
- Loss on walkaway from partnership - is it ordinary or capital?
- Irrevocable trusts and the generation-skipping tax.
- When can partnership interests be exchanged tax-free?
- High income married taxpayers should consider filing separate returns for 1991.
- Must developers comply with Rev. Proc. 75-25?
- Federal election for reduced R & D credit can be state tax planning opportunity.
- Reconsidering the election to segregate rental real estate undertakings.
- Saving the S election; an analysis of recent letter rulings suggests that the IRS has been reasonable in granting waivers of S termination.
- Insured business losses; if they are unclaimed they may still be deductible.
- CPA-client privilege vs. the confidentiality ethics requirement.
- Maximizing the investment interest expense deduction.
- Regular tax and AMT NOLs subject to single carryback waiver election.
- IRS issues guidance on IRA revocations.
- Distributions from split-interest trust are not included in distributable amount; Regs. Sec. 53.4942(a)-2(b) (2) is invalid.
- IRS sets rules for SLOB determination letters.
- Hospital's joint venture with its medical staff could jeopardize exempt status.