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.