Vol. 27 No. 6, June 1996
Index
- Hybrid cash-accrual method found to clearly reflect income.
- Busting a "B": why and how, Letter Ruling 9508009.
- Sec. 351 transfers as "bargain purchases."
- New elections available in wake of final consolidated return regulations.
- Final consolidated zero-basis regulations fix part (but not all) of the problem.
- Charitable contribution substantiation requirements for estates and complex trusts.
- Who must file Form 1041-A?
- Final regulations on new grantor trust reporting requirements.
- QPRTs - determining the tax-optimal trust term.
- Distinguishing church plans under ERISA and the Code.
- Acquisition-related compensation not capitalized under INDOPCO.
- 6th Circuit allows rental losses under sec. 280A.
- Stock option plan amendment not material for sec. 162(m).
- Planning opportunity for certain "J" visa holders.
- The deductibility of traveling expenses for foreign nationals on U.S. internships.
- IRS guidance on the empowerment zone employment credit.
- Short sales against the box: an endangered income tax planning technique.
- Taxation of equity split-dollar arrangements.
- Taxable rent-free lodging ruling applies retroactively.
- Select-group qualified nonelective contributions.
- Planning opportunity for surviving spouse who is beneficiary of IRA and qualified plan.
- Court limits Service's ability to assess FICA tax on unreported tips.
- District court orders IRS to release field service advice memoranda under the FOIA.
- Adlman court holds work-product doctrine is inapplicable to pretransaction memoranda.
- Classification settlement program.
- New applications of the integrated plant doctrine to sales and use tax manufacturing exemptions.
- State support for MTC's aggressive positions wanes.
- Final regs. clarify basis and distribution issues, but leave unanswered questions.
- Smoky Mountain's secret to successfully claiming workers to be independent contractors.
- The Tax Court exam.
- Sales management for tax practices.
- States enamored with deceptively attractive "Geoffrey nexus" position.
- Allocations using a reasonable method other than those specifically stated in regulations.