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.