Vol. 24 No. 6, June 1993
Index
- Proposed S corporation regulations under Secs. 1367 and 1368.
- Rev. Proc. 92-33 is applied to LLCs.
- New proposed regulations on tax-exempt real estate ownership.
- Options as a shield against a sec. 382 ownership change.
- Partnership must delay sec. 734(b) adjustments until retiring partner recognizes gain or loss.
- Purchases of stock and a covenant not to compete: a trap for the unwary.
- Caveat: recent letter ruling raises issue of whether sec. 304 applies in domestic spin-off transaction.
- IRS letter ruling 9306001: a window of opportunity to sell publicly traded stock and use the installment method.
- Employer files wrong return - SOL not triggered.
- Unable to pay? Installment agreements are viable options.
- Current deduction vs. capitalization of fees for shelf space - IRS circulates draft proposed coordinated issue paper.
- Refunds may be available for clients who did not literally follow the substantiation requirements for certain charitable contributions of property.
- Bankruptcy court cannot partially disallow penalties.
- IRS revokes favorable royalty ruling.
- Corporate sponsorship proposed regulations issued.
- Exempt bond 'private use' rules updated.
- Charitable gift annuities as a planning technique.
- Taking advantage of low interest rates.
- Nonresident aliens: U.S. estate tax on treasury bills.
- Transfer-for-value rule.
- IRS blesses short-term, high-income GRATs.
- Obtaining participant consent to benefit distribution.
- Exempt employer's excise tax for nondeductible contributions to qualified plan.
- Nonlapse restrictions.
- Payment for suicide allegedly caused by job stress is excludible.
- Can a 401(k) plan be a qualified replacement plan?
- No deduction for high-rate dividend used to pay off ESOP loan.
- Union plan is tax exempt as labor organization.
- Life insurance in qualified plans.
- IRS announces temporary suspension for filing accounting method change requests for loan origination costs.
- IRS will allow lenders to defer sec. 461(g) (2) points as OID.
- Certain foreign nationals may avoid penalties for underpayment of estimated tax by relying on 100% of prior year tax shown on dual status return.
- National Bank's core deposit amortization upheld by Tenth Circuit.
- Proposed regulations on debt modifications - are grandfathered earnings stripping obligations in jeopardy?
- Government finally tells taxpayers that they can't bump and strip.
- U.S. Supreme Court vacates and remands Texas decision striking down tax on domestically owned cargo containers used in international shipping.
- U.S. Supreme Court resolves escheat controversy involving states' conflicting claims to abandoned securities distributions.
- Withdrawal from a partnership after Citron and Echols.
- Using practice management tools within tax software.
- Income tax vs. gift tax - dependants as donees.