Vol. 25 No. 3, March 1994
Index
- Troubled debt transactions.
- IRA contributions by foreign nationals: long-term investments with short-term returns.
- Adverse consequences to U.S. shareholders of PFICs.
- Recent developments in LLCs.
- Sec. 197 anti-churning rules don't apply to assets amortizable under prior law.
- Capitalization of portfolio management fees.
- Deducting a portion of the costs of sec. 197 intangible assets over a shorter period.
- Electing premium amortization on taxable bonds.
- Using options to compensate service providers at the formation of a new entity.
- Automatic two-month extension to file return for those with tax homes outside the United States and Puerto Rico.
- Other properties received in a stock spinoff.
- Treatment of property other than stock received in a merger or acquisition.
- Foreign corporations may be entitled to additional extension for filing returns.
- IRA contributions by high school and college-age children.
- Use of a dynasty trust in estate planning.
- Deductibility of temporary assignment living expenses.
- How owners of closely held businesses can use minority valuations to lower estate taxes.
- RRA prompts fresh look at ISOs for corporate executives.
- Estimated inventory shrinkage is not a reserve - or is it?
- Deducting interest in deferred compensation arrangements.
- Tax deficiency interest ... personal or business?
- Financial statement conformity no longer required in change in accounting method consent letter.
- New regulations clarify partnership allocations related to contributed property.
- Third-party liability for withholding taxes under Sec. 3505.
- Unraveling the mysteries of Sec. 304 in international tax planning.
- An update to the COD provisions amended by the RRA.
- Constructive ownership rules and related party transactions.