Vol. 37 No. 6, June 2006
Index
- AICPA requests guidance on use of PTCs.
- IRS outlines prohibited behavior for charities during political elections.
- IRS warns taxpayers against frivolous arguments.
- Tuition prepayment by donor not subject to gift or GST tax.
- IRS clarifies direct labor costs cannot be MSC.
- UNICAP errors, omissions and opportunities: TAM 200607021.
- Taxpayer successful in establishing no successor.
- Are taxpayers properly paying the federal foreign insurance excise tax?
- Interplay between the Sec. 199 manufacturing deduction and the Sec. 965 repatriation provision.
- Variable prepaid forwards: are stock loans possible in light of TAM 200604033?
- IRS tightens vehicle donation rules.
- How much authority do revenue rulings have?
- Allocation and apportionment of expenses for Sec. 199 purposes: for many taxpayers, calculation of the Sec. 199 deduction will require an enormous amount of work. This article focuses on one aspect of the deduction, the allocation and apportionment of expenses under the Sec. 861 regulations and the proposed Sec. 199 regulations.
- Tax accounting issues for foreign trusts: this two-part article describes tax accounting and reporting consequences of foreign and domestic trusts. Part I defines these trusts and discusses some advantages and disadvantages of foreign trust status.
- Below-market loans may have unexpected tax results: tax advisers should be aware of the type of arrangements subject to imputed interest rules under Sec. 7872. This article describes the major types of below-market loan transactions, as well as the exceptions and how the rules apply to such transactions.
- Divesting clients wisely.
- Will the push for origin-based sourcing derail SST?
- Bank Tax Guide.
- Deduct It!(Brief article) (Book review)
- Electronic Commerce: Taxation and Planning.
- Tax Savvy for Small Business, 9th ed.
- Taxation of Regulated Investment Companies and Their Shareholders.
- Reviewing LLC documents for new or existing clients.
- Mixed expense reimbursements and unreturned overpayments disqualified entire accountable plan.
- Adoption requirements qualified as unforeseen circumstances for principal residence exclusion.
- Clarification.