Vol. 23 No. 6, June 1992
Index
- Highlights of the new taxpayer accuracy-related penalty rules.
- Special estimated tax rules.
- Renting below FMV may result in lost deductions due to vacation home rules.
- IRS investment interest expense ruling applies a very broad interpretation of property held for investment.
- Window of opportunity for tax-exempt repatriation of substitute payments in cross border securities lending transactions.
- Banner year for state tax cases before the U.S. Supreme Court.
- Tax-free reorganization for great-grandparent stock.
- SAR's are not Sec. 382 "options." (stock appreciation rights do not qualify as stock options)
- Lower interest rates make GRATs and GRUTs and attractive tax planning technique.
- Loan fees: deductible even if proceeds of loan are used for a redemption.
- Realized and unrealized gains or losses on plan assets for form 5500 reporting purposes.
- Ministerial acts after General Dynamics.
- Defective grantor trust may offer valuable transfer tax benefits.
- Taxable mortgage pool rules now in effect.
- Sale-leaseback may offer more benefits than reverse mortgage.
- PFICs: some new twists to old rules.
- IRS revokes ruling that employer-provided lunches are nontaxable to employees.
- Relief for defined contribution plans with investments in life insurance companies in state liquidation proceedings.
- Disclaimer of plan benefits or IRA by spouse if a decedent is not a prohibited assignment or alienation.
- Coordinating plan loans and hardship distributions.
- Valuable planning opportunity available using GRATs or GRUTs.
- Legislation on the amortization of intangibles.
- Taxpayer's right to receive payments under an annuity policy is income when annuity is purchased.
- IRS disqualifies plans when investment options offered only to prohibited group.
- District court says excise taxes were inappropriate when plan was not harmed.
- IRS denies relief to government employers.
- IRS severely limits methods of disclosure.
- Sale of residence before end of term may produce extraordinary benefits for QPRT beneficiaries.
- Court holds employer liable for COBRA coverage even though employee was not eligible.
- District Court says indirect transfer to new plan results in reversion under pre-RRA rules.
- IRS limits planning for lump-sum distributions.
- IRS reviews life insurance benefits paid to terminally ill.
- Recent rulings illustrate use of joint tenancy disclaimers in postmortem estate planning.
- Discount partnership arrangements still can be used to reduce transfer taxes.
- Recent cases examine definition of ERISA "plan."
- Estate planning for S shareholders: maintaining qualification after death in common estate planning situations.
- IRS may allow rollovers of IRA distributions received from RTC even if previously rolled over within the past year.
- Realty rental S Corporations: those with excess passive investment income and C earnings and profits face a dilemma.
- When to advise a Sec. 754 election.
- Extending the benefits from a voluntary tax practice review.
- Privilege and confidentiality: confusing principles.
- Professional liability in a tax practice.
- Timing Sec. 1231 gains to avoid the "lookback" provisions.