Vol. 25 No. 7, July 1994

Index

• Irrevocable life insurance trusts.
• Nexus through the presence of intangibles.
• Maximizing FSC benefits for software companies.
• LLPs: a new form of organization.
• RRA complicates charitable deduction status of travel expenses.
• Sec. 29 nonconventional fuels credit: 1993 highlights.
• Sec. 1202 can benefit investors in an S corporation.
• Calculating "in-house" lobbying expenses under IRS safe harbors.
• Corporate downsizing - tax treatment of leased employees.
• Earnings stripping and foreign-owned controlled groups.
• Transfer pricing penalty pitfalls.
• Settling pending intangibles disputes - IRS guidance.
• Tax strategies available under income forecast method.
• Charitable contribution deductions - an alternative to capitalization of demolition costs.
• IRS releases favorable sec. 263A accounting method change guidance.
• Avoiding potential disallowance of foreign branch losses.
• Final OID regulations provide guidance on debt instruments.
• Sec. 351: an alternative to taxable asset acquisitions.
• Spousal rollover rights when trust is qualified plan beneficiary.
• IRS positions threaten RTC under fixed-price contracts.
• Sec. 304: IRS reconsiders "foreign subsidiary stock transfer" rulings.
• Using S losses to generate future capital gains - planning opportunities available for shareholders with capital losses.
• Cash method taxpayer must realize gain/loss on sale of stock in year of trade.
• Contested liabilities - when is a deduction allowed?
• Prohibited transactions for qualified employee benefits plans.
• Computer usage and tax software in a tax practice: AICPA tax division survey results.
• Minimizing gain recognition on the sale of a residence when two homeowners marry.