Vol. 29 No. 6, June 1998
Index
- Simplified production method with HAR election is permitted if taxpayer's actual absorption ratio significantly exceeds HAR.
- Some taxpayers may automatically change their method of accounting for inventory shrinkage.
- Commonly encountered provisions overridden by Sec. 1502 regs.
- Intangibles were shareholder's assets, not corporate property.
- The direction of a merger: pitfalls and opportunities.
- Mergers of entities and nonentities: the shape of things to come?
- Reflections on the new COBE regs.
- Securities exchanges incident to B reorgs.
- TRA '97 and Sec. 355.
- Alaskan self-settled trusts.
- IRS, TC bound by revenue ruling.
- IRS permits NIMCRUT to invest in deferred annuities.
- Purchase of QTIP remainder interest for FMV is a gift.
- Coordinated issue paper gives guidance on underground storage tanks.
- Compensation committee passes Sec. 162(m) muster with recusal of non-outside directors.
- Foreign reporting rules should encourage voluntary compliance.
- Treasury fulfills promise to issue Brown Group partnership regulations.
- New FSC grouping regulations: a disappearing opportunity.
- New PFIC QEF election regulations encourage purging PFIC taint of a CFC/PFIC for 1997 tax year.
- Proposed small business taxpayer APA procedures.
- Regulations issued for Notice 98-11.
- Ruling highlights mismatch between Subchapter C and Subpart F for deemed dividend of previously taxed income arising from redemption of CFC stock.
- Interest income and deductions in marital property settlements.
- Treasury bolsters its position on contract manufacturing.
- ESOP stock sale proceeds not subject to Sec. 415 limits.
- Former employee not entitled to full vesting if plan and employer terminated simultaneously.
- Planning with welfare benefit plans after the Prime Financial decisions: a case for caution for Sec. 419A(f) (6).
- Revocable trusts can be named as qualified plan beneficiaries.
- Closing a case: the form used can expand or limit taxpayers' options.
- Defining business/nonbusiness income.
- Information reporting by attorneys for payments to experts.
- States warned against using "bait-and-switch" tactics in denying refunds of unconstitutionally collected taxes.
- Capital gains after the TRA '97 - tax relief or mental strain?
- The responsibilities and obligations of the tax matters partner.
- Envisioning the future of tax practice.
- Significant state practices and amnesty programs.
- Loan proceeds and passive activity losses.