Vol. 28 No. 5, May 1997
Index
- Copy of Form 3115 to IRS National Office under automatic procedure provides audit protection.
- Maneuvering through the sec. 381 regulations' accounting method rules.
- Proposed change to continuity-of-shareholder-interest requirement in acquisitive reorganizations.
- Reducing corporate AMT on an employee's stock option exercise.
- Subsequent dropdowns to partnerships in corporate reorganizations.
- Noncompete agreement entered into contemporaneously with stock redemption.
- Don't overlook the credit for tax on prior transfers.
- Gifts of closely held business stock may sacrifice future savings.
- One plus one equals two - sometimes! (estate tax valuation of property held in a qualified terminable interest property trust)
- The Crummey Road.
- Capitalization of repair costs mandated by law.
- Passthrough investments by exempt organizations.
- Deductibility of fees paid to postpone property settlement.
- Using Form W-7 to obtain ITINs.
- How do intermediaries affect related-party exchanges?
- Proposed regulations affect form of funding international operations.
- IRS cracks down on self-amortizing investments in conduit financing entities.
- IRS is rethinking its position on sec. 1031 followed by a corporate reorganization.
- Taxation of personal injury and sickness awards.
- Transfer of encumbered property to corporation can have negative tax consequences.
- Self-employment tax and the LLC member: a uniform approach.
- Sec. 704(c)'s anti-abuse rule: a practitioner's guide.
- Is sec. 704(c) or sale treatment better for a contributing partner?
- Guidance issued on the allocation of depreciation recapture from partnership dispositions.
- Employers may provide option to postpone minimum distributions.
- IRA garnished for child support subject to tax plus penalty.
- New self-correction policy for retirement plans.
- Mitigation of the SOL on refund claims.
- SOL on trust fund recovery assessments.
- When can losses be deducted against S corporation basis?
- Kroger brings clarity, confusion and controversy to Illinois.
- Type of entity determines treatment of nonresident owners of N.C. investment activities.
- Avoiding the 35% penalty on failure to report outbound transfers to foreign entities under sec. 1494(c).
- Check-the-box final regs. simplify entity classification.
- Current income tax treaty developments.
- AICPA speaks out on tax issues.
- The model tax curriculum - tax education for the 21st century.
- Avoiding the pitfalls associated with attempts to recharacterize activities.