No. 56-5, May 2025

Index

• 'Looking through' income tax apportionment for service providers.
• Adequate disclosure on gift tax returns: A requirement for more than gifts.
• Apportioning tax benefits among members of a controlled group.
• Court allows Sec. 7431 tax information disclosure claim to go forward.
• Deferred revenue: Transactional triggering events.
• Handwritten signature not needed on electronically generated petition.
• How S elections go wrong and how to fix them.
• ING trusts: How they work and their continued viability. (incomplete gift nongrantor trust)
• Integrating personal financial planning into individual income tax courses.
• Navigating the complex interplay between Secs. 108(e) (6) and 367(c) (2).
• Partnership reporting of contributions to foreign entities.
• Sec. 541: A trap for the unwary investment partnership.
• Sec. 987 final regulations: A practical approach for partnerships.
• Tax accounting method changes: Procedures and potential issues during an IRS exam.
• Tax planning for health care management services organizations.
• Tax planning for inpatriates.
• Why non-US directors can rarely exempt US-source compensation from US income tax.