The Tax Adviser
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- Significant recent corporate developments.
- IRS positions threaten RTC under fixed-price contracts.
- Using trusts to shift income to children.
- Life insurance policy exchanges.
- New employment tax reporting procedures in business acquisitions.
- ETI and IC-DISC export tax benefits for government contractors.
- Common pitfalls in information reporting.
- Preparing to work indirectly with the cannabis industry.
- Common mistakes in life insurance arrangements.
- Exceptions to branch profits tax available to foreign corporations with U.S. tax compliance obligations.
- The calculation of interest when an original overpayment is decreased on audit.
- The "new" IRS audits.
- Expanded innocent spouse relief.
- Latest developments in information reporting.
- LLC may limit choice of accounting method.
- Managing incentive compliance.
- "Convenience of the employer" after Boyd Gaming Corp.
- Opportunity zone penalties: What constitutes reasonable cause?
- When does it make sense to elect out of the installment method?
- Electing sec. 179 for property used in a rental activity.
- Navigating the complex interplay between Secs. 108(e)(6) and 367(c)(2).
- Homeland Security may contact U.S. persons living abroad who owe back taxes.
- New equipment leasing LLCs may avoid SE tax.
- Post-EGTRRA analysis and planning (Estates, Trusts & Gifts).
- Tax practice responsibilities: taxpayer representation in the shadow of preparer discipline.
- Asset protection caveats when using family limited partnerships as an estate planning vehicle.
- Proposed regulation classifies LLC members for self-employment tax purposes.
- Loan guarantees were prohibited transactions that disqualified IRAs.
- Amnesty for offshore tax evaders.
- Dental practice's management fees were not ordinary and necessary business expenses.
- When is a rental not a rental?
- Tax Court petition filing by nonattorneys.
- AICPA RESOURCES.
- Violation of public policy and the denial of deductions.
- The impact of filing status on student loan repayment plans.
- Amounts borrowed from fellow S shareholder not at-risk for basis purposes.
- Cottage Savings regulations finalized in conjunction with newly issued bad debt regulations.
- Qualified decedents' estate tax.
- Supreme Court decides Maryland's personal income tax scheme violates the "dormant" commerce clause.
- New repatriation dividend deduction.
- The qualified therapeutic discovery project tax credit and grant.
- Transnational tax information reporting: A guide for the perplexed.
- Sec. 409A's application deferred.
- Loss on disposition of stock disallowed unless statement is filed.
- Regulations issued for Notice 98-11.
- Capital gain compliance.
- National taxpayer advocate's report notes serious problems.
- IRS ruling clarifies treatment of R&D when computing the FDII deduction.(research and development services in foreign-derived intangible income computation)
- The new passive activity regulations: simplification at last?
- How S elections go wrong and how to fix them.
- Considerations on whether to check the box for foreign subsidiaries.
- Lifetime tax planning for LLC owners.
- Job Creation and Worker Assistance Act of 2002.
- FATCA withholding on payments to nonfinancial foreign entities: a broad new requirement.
- Final regs. provide guidance on S corp. treatment of COD income.
- Correcting property contributions to qualified plans.
- The AJCA's domestic business provisions: the American Jobs Creation Act of 2004 (AJCA) is an expansive piece of legislation touching many types of taxpayers. This article discusses the AJCA provisions that primarily affect U.S. domestic businesses.
- Withholding tax on foreign mortgages.
- Sec. 7874: new Regs. tighten the anti-inversion rules.
- Dismissal of tax-driven bankruptcy plan affirmed.
- Property Sale to Satisfy Debt to Ex-Spouse Was Not Incident to Divorce.
- ESOPs and S Corporations.
- S Shareholders Not Entitled to Increase Bases by Guarantee of Corporate Debt.
- Interaction of the subpart F dual-character property and majority-use rules.
- Costs of defending against hostile takeover must be capitalized, if future benefit results.
- Loans from qualified plans to owner-employees can be prohibited transactions.
- ATNOLs and charitable contribution carryovers: which takes precedence?
- Qualified zone academy bonds.
- Implementation issues for the Mexican nonresident income tax.
- Prop. Regs. create capital gains and losses for non-bank lenders.
- Practical advice on current issues.(TAX CLINIC)
- Computing the Sec. 4975 excise tax for failure to timely deposit elective deferrals.
- IRS suspends filing requirements for certain fringe-benefit plans.
- Institute for Professionals in Taxation (IPT).
- IRS reclassifies royalties as wages.
- Stock received in demutualization has no basis.
- Automobile dealers may use replacement-cost method to approximate vehicle-parts inventory cost.
- Bridge to an updated automation guide.
- Stellar tax professionals: How to recruit, retain, and develop them.
- Practice and policy insights from academic tax research.
- Tax lien attached to property transferred in divorce.
- New retirement savings incentive may be an opportunity for "retirees".
- Guidance on unforeseeable emergency distributions.
- Practical advice on current issues.(TAX CLINIC)
- The number of no-change audits is a concern.
- IRS affirms deductibility of some - but not all - computer software development and implementation costs.
- September 11 tax relief: electing out of mid-quarter depreciation.
- Foreign national tax planning to avoid PFIC trap.
- Tax aspects of contributing a house to a fire department.
- Consolidated returns and E&P - application of Sec. 1503(e) to preaffiliation property.
- Penalty for failing to file information returns on certain outbound transfers of property substantially expanded.
- Look-back method for long-term contract reporting.
- Sec. 409A: international issues.
- IRS allows deduction to AGI for certain tax-related payments.
- SILO legislation.
- Prop. regs. on partnership withholding on foreign partners.
- Home Interiors - more work for the Texas legislature?
- IRS announces a "breakthrough" plan.
- Understanding how corporate dividends are taxed to shareholders.
- Effect of nondeductible, noncapital expenses on S stock basis and taxable income.
- AICPA tax division distinguished service award.
- Fast Track Settlement program extended to small business.
- Gains on sales of QSB stock in light of secs. 1045 and 1202.
- S Corporation holding company had to recapture pro rata share of LIFO reserves.
- Worldwide Tax.
- Practical advice on current issues.(TAX CLINIC)
- Medical residents subject to FICA.
- IRS curbs use of Crummey powers.
- Substantiation and disclosure requirements for charitable contributions.
- Till death do us part: dealing with carryovers when a spouse dies.
- Refuting IRS challenges to the use of FLPs.
- Sec. 465 traps for the unsuspecting S corporation shareholder.
- States increase enforcement of unclaimed property laws.
- Significant recent developments in estate planning.
- Miscellaneous inflation adjustments.
- IRS issues final regs. on marital-related stock redemptions.
- Tax advantages of LLCs in farm operations.
- Establishing a Sec. 401(k) plan.
- Many Unhappy Returns: One Man's Quest to Turn Around the Most Unpopular Organization in America.
- Computing the charitable income tax deduction for a single-life CRAT.
- Current developments.
- Affirmation of consolidated return regulation authority.
- Self-certification spells relief for late IRA rollovers.
- Timeshare rental activity was trade or business activity giving rise to ordinary loss on foreclosure.
- Continuing efforts to amend the multistate tax compact.
- Is it still the alternative minimum tax?
- Captive insurance companies: opportunities and pitfalls.
- Acquisitions by S corporations - -beware the QSub election.
- Prop. regs. govern charitable contribution substantiation and reporting.
- Tax Court Courtesy Calls.
- Sec. 179 expensing election.
- Applying the above-the-line deduction for certain legal fees.
- Nonqualified deferred compensation agreements: tax and ERISA requirements.
- Recent developments in estate planning.
- Impact of Medicare tax on deferred compensation.
- Tax Savvy for Small Business, 9th ed.
- The new GILT and repatriation taxes: Issues for flowthroughs.
- IRS issues proposed anti-loss-duplication consolidated regs.
- Election to treat revocable trust as part of estate for income tax purposes.
- IRS posts guidance on changing from C corp. to S corp.
- Deferring shareholder gain by distributing installment notes.
- Partnership reporting of contributions to foreign entities.
- The research credit: Documenting qualified services.
- U.S.-Canada income tax treaty requires income of U.S. branch to be determined under facts and circumstances.
- IRS extends reliance period for certain retirement plans to 1999.
- HR 22.
- Walking the Sec. 1202 minefield.
- Hurricane Katrina: IRAs, sec. 401(k)s and similar retirement plans.
- Personal goodwill: alive and well?
- Electing S corporation status for a limited liability company.
- Should taxpayers invest in the new Roth 401(k)?
- Qualified improvement property and bonus depreciation.
- Pre-U.S. immigration estate planning for nonresident aliens.
- Planning for the Medicare Part B premium.
- Online AMT calculator.
- Sec. 987 final regulations: A practical approach for partnerships.
- Deloitte International Tax and Business Guides.
- New forms and transitional rules for withholding tax.
- Will a Crummey beneficial interest qualify for an annual gift tax exclusion?
- President proposes tax relief for the middle class in State of the Union.
- Repeal of Sec. 457 coordination requirements.
- Estate planning for S shareholders: maintaining qualification after death in common estate planning situations.
- Hardship waiver from electronic-filing requirement for large partnerships.
- Initial IRS guidance addressing EU cap-and-trade systems, subpart F rules.
- Purchase of QTIP remainder interest for FMV is a gift.
- Practical advice on current issues.
- Travel and entertainment rules from a practice development point of view.
- Guidance on accounting method changes for intangibles.
- Temp. regs. issued on obligations arising from certain upfront payments by CFCs.
- What to do when a client dies.(estate and trust administration by CPAs)
- New applications of the integrated plant doctrine to sales and use tax manufacturing exemptions.
- Integrating technology into accounting curriculum as CPA Exam evolves.(certified public accountants)
- IRS clarifies Rev. Proc. on partnership interest for services.
- Cost-segregation studies and the impact of the tangible property regulations.
- Revenge of the nannies: "Nanny Tax" bill finally signed into law.
- Surviving a partnership audit: success depends on selecting the right tax matters partner.
- Power of attorney revoked due to taxpayer's mental incompetence.
- Deductibility of exit and entrance fees paid to the FDIC.
- Sec. 1402(a)(13) and limited partnerships.(Internal Revenue Code, Soroban Capital Partners L.P.)
- Tardy to the e-filing party.
- Cash payments to former spouse not alimony.
- Tax expert or rainmaker?
- New DOL rules increase scrutiny of IRA trustee fees: CPAs should be careful before agreeing to be trustees of IRA trusts and should consider especially whether any fees charged might be excessive.
- QTP contributions by nonindividuals.
- Treating a refund request made on an incorrect form as an informal refund claim.
- Applying for a fiscal year under Sec. 444 when an S election is made.
- "Homemade" income tax forms may constitute valid returns.
- Organization costs and start-up costs amortized over 15 years.
- Changing an impermissible LIFO method.
- New VAT rules regarding international services.
- Burden of proof shifts to IRS.
- Revenue Reconciliation Act of 1993; Voluntary Compliance Resolution program; fiduciary responsibilities; distribution rules; excise taxes.
- The challenges of state transfer pricing.
- Sec. 541: A trap for the unwary investment partnership.
- Frequent-flyer miles attributable to business travel are not taxable.
- Does Norwest expand INDOPCO's reach?
- Effect of OID final regs. on private annuities.
- S holding companies and F reorgs.
- Duty of consistency precludes taxpayers' argument.
- Expeditious approval of accounting period changes.