Vol. 26 No. 6, June 1995
Index
- Minimizing AGI-based deduction limits by shifting family income: big savings possible despite the kiddie tax.
- Termination for gross misconduct and COBRA rights.
- Correcting property contributions to qualified plans.
- FICA and FUTA taxes for deferred compensation.
- Termination of retiree health benefits.
- Restoration of plan investment losses is not a contribution.
- Transfers from money purchase plan to profit-sharing plan.
- Employer payments for club dues, meals, entertainment and spousal travel.
- Field directive says part-timers cannot be excluded.
- Property transferred in connection with performance of services.
- When does the cash method clearly reflect income?
- Pitfalls under new sec. 959 ordering rules.
- Filing of Form 3115 may be necessary by June 19, 1995 to obtain automatic approval (including audit relief) for changes to comply with final interest capitalization regulations.
- Attribution rules applicable to commercial activities or controlled commercial entities of a foreign government for sec. 163(j) purposes.
- Gift tax return SOL - exception to the general rule.
- Increasing-annuity payments make GRAT more attractive.
- TAM 9452002: redefining "control." (Technical Advice Memorandum)
- Availability of 10-year carryback should be considered in light of IRS's ruling position.
- Closed year NOL may be increased if carryover year is open.
- Gasoline wholesalers should consider opportunities presented by special gasoline tax refund procedure.
- Short-term capital gain distributions from a RIC - accounting income or corpus?
- Incorporations and reorganizations involving qualified small business stock.
- Resurrecting transactions to qualify under secs. 338 and 338(h) (10).
- Consolidated return election may mitigate stock basis decrease from phantom item.
- Business/nonbusiness income distinction subject to challenge.
- Proposals for comprehensive tax reform.
- Technological obsolescence may result in reduced personal property tax assessments.
- Minimizing the generation-skipping transfer tax with thoughtful use of the $1 million GST exemption.
- Continuing levy notice held applicable to commissions due independent contractor.
- Sec. 338(h) (10) - caveat target!
- Sec. 197 antichurning rules - application of election to recognize gain on a sale of goodwill between related partnerships.
- Avoiding penalties for failure to pay AMT: computation's complexity may abate penalties for individuals.
- U.S. taxation of nonimmigrant students, teachers and trainees.
- The audit lottery, or preparing for the TCMP audit - again! (Taxpayer Compliance Measurement Program)
- Determining the effects of a sale of deceased partner's interest by the successor in interest.