No. 56-1, January 2025
Index
- Arthur J. Dixon Memorial and Jonathan Horn Distinguished Service awards.
- Automatic consent to Sec. 174 accounting method changes modified. (Internal Revenue Code)
- Basket contracts would be listed transactions under proposed regs.
- Ensuring that shareholder debt is not reclassified as equity.
- Expenses that could have been substantiated not allowed.
- IRS FAQ clarifies sunset of Notice 2010-46 credit forward framework.
- New prop. regs. limit taxpayers' foreign currency elections.
- No Collection Due Process hearing for FBAR penalties. (foreign bank account reporting)
- Profits interests: The most tax-efficient equity grant to employees.
- Proposed regulations update QDOT regulations. (qualified domestic trust)
- Seller beware: Repossessions in real estate installment transactions.
- Strategies for information return penalties and Form 945 assessments.
- Taxpayer may not deduct penalties imposed for violating a law.
- Treasury provides guidance on the interaction of DCLs with Pillar Two taxes. (dual consolidated loss rules)
- Using the IRS's BBA Online Form Submission Service. (Bipartisan Budget Act of 2015)