The Tax Adviser
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- Falling federal interest rates can precipitate interest disallowance.
- Latest developments in information reporting.
- Preparing to work indirectly with the cannabis industry.
- Massachusetts offers dueling standards for employee/contractor status.
- Strategic Corporate Tax Planning.
- Stock received in demutualization has no basis.
- IRS will not rule that risk reduction alone is a valid business purpose under Sec. 355.
- The calculation of interest when an original overpayment is decreased on audit.
- Updates and guidance on key IRS practice developments.
- ISOs and AMT: improving the odds when gambling with the IRS.
- IRS announces FY 2014 sequester reduction rate for qualified refundable credit bonds.
- Avoiding double taxation - an employment tax savings opportunity.
- IRS tightens vehicle donation rules.
- S Corporation passive income.
- Method change from LIFO inventory method under Rev. Proc. 97-37.
- Practical application of the new MACRS depreciation regs.
- Statutory mergers.
- Choice of entity: benefits of a partnership.
- Guidance on required electronic FTDs.
- 2015 tax software survey.
- IRS loses estate tax marital deduction case.
- Chief counsel disregards indemnification agreements under anti-abuse rules in transactions that result in disguised sales.
- "Convenience of the employer" after Boyd Gaming Corp.
- Qualified decedents' estate tax.
- Sec. 409A's application deferred.
- Dismissal of tax-driven bankruptcy plan affirmed.
- 1996 tax legislation offers planning opportunities.
- Schedule UTP: IRS mandates disclosure of uncertain tax positions.
- Transfer of stock warrants to charity was not an anticipatory assignment of income.
- Qualified zone academy bonds.
- TEC initiatives.
- Prop. Regs. create capital gains and losses for non-bank lenders.
- Interplay between sec. 174 and sec. 41 for software development activities.
- Sect. 183 special limitation period modifies general three-year SOL.
- Tax lien attached to property transferred in divorce.
- Navigating the real estate professional rules.
- Practical advice on current issues.
- Nonqualified deferred compensation agreements: tax and ERISA requirements.
- The new GILT and repatriation taxes: Issues for flowthroughs.
- IRS issues proposed anti-loss-duplication consolidated regs.
- Deductibility of retirement community fees.
- Election to treat revocable trust as part of estate for income tax purposes.
- Deloitte International Tax and Business Guides.
- All aboard: the impact of the New York state MTA payroll tax on alternative investment fund managers.
- Partnership property transactions: exploring the limits of Secs. 704(c) and 707(a)(2).
- Claiming the credit for residential energy-efficient property.
- Application of Sec. 382 to foreign corporations.
- IRS flexes its muscles under the partnership anti-abuse rules.
- Lump-sum distributions of employer stock present opportunities.
- The importance of a well-drafted LLC operating agreement.
- Interaction of the subpart F dual-character property and majority-use rules.
- Ruling on the deductibility of commuting expenses disagrees with Walker but expands the unanswered questions.
- Superseding return filed on extended due date starts SOL.
- Repeal of Sec. 457 coordination requirements.
- Estate planning for S shareholders: maintaining qualification after death in common estate planning situations.
- Trust's investment advisory fees.
- Limitation period for equitable innocent spouse relief held invalid.
- Practical advice on current issues: new directives from the LMSB.
- Post-JGTRRA investment management strategies.
- The "new" IRS audits.
- Totalization agreements.
- Simplification of third-party authorization process.
- Valuing partnership interests acquired in exchange for services.
- Family Trust Planning Guide.
- Capitalization of environmental cleanup costs.
- Depreciation of property received in a like-kind exchange.
- Avoiding the self-rental trap.
- Convert C corporation to S corporation at retirement for passive income.
- Guaranteed payments for the use of capital may result in self-employment tax.
- Potential loss of contribution carryforwards in AMT.
- International students and the American opportunity tax credit.
- Deductibility of exit and entrance fees paid to the FDIC.
- New rules for requesting accounting method changes.
- When is a rental not a rental?
- 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.
- Postliquidation payment on loans guaranteed by a shareholder.
- Deductibility of temporary assignment living expenses.
- Excluding and rolling over gain on disposition of qualified small business stock.
- DOL issues guidance concerning misclassification of employees and independent contractors.
- Election day 2016: voters to decide key business tax matters.
- Partnership depreciation trap.
- IRS plans regs. on sec. 909 foreign tax credit splitter arrangements.
- Sec. 1341(a) income tax benefit is includible in the gross estate.
- Cost-segregation studies and the impact of the tangible property regulations.
- Getting the most from individual charitable contributions.
- Surviving spouse's depletion on community property for year of deceased spouse's death.
- Tax practice responsibilities: tax practice quality control.
- Ex-spouse was entitled to intervene in "innocent spouse" suit.
- Planning ideas under the new consolidated sec. 382 regulations.
- Structuring divisive reorganizations.
- TIPRA covers some issues, neglects others.
- RRA changes affecting discharge of indebtedness income.
- IRS made 'initial determination'.
- Is a single-employer welfare benefit plan appropriate for a small business?
- Current developments in employee benefits.
- Interest netting strategies: Northern States Power decision.
- Environmental excise taxes imposed on chemicals and substances.
- What is reasonable compensation?
- Final regs. on partnership allocations of CFTEs.
- Software enhancements lacked requisite innovation and scientific experimentation for R&D credit.
- A quirk in the TCJA's small business exceptions.
- Tax planning for elderly clients.
- Gift tax paid on transfer of QTIP remainder included in estate.
- IRS revokes "mirror" sec. 401(k) ruling.
- Tax extenders are enacted.
- Joint Committee on Taxation (JCT).
- Deducting costs that are usually capitalized.
- Recent guidance raises long-standing issue of what is a separate trade or business.
- Electing sec. 179 for property used in a rental activity.
- IRS disallows write-off of startup and organizational costs in a technical termination.
- Practical advice on current issues.
- Protection from creditors for retirement plan assets.
- New law expands IRA deduction for homemakers.
- Increased Sec. 179 expense limits extended two years.
- Clarification.
- FBAR penalties reduced for six months.
- Taxability of lump-sum ESOP distributions at employment termination.
- Transfer price adjustments don't necessarily increase import duty costs.
- Presubmission conference pilot program for technical advice issues.
- Considerations for filing composite tax returns.
- Tax Court had no jurisdiction over nonrequesting spouse's petition.
- Ruling highlights mismatch between Subchapter C and Subpart F for deemed dividend of previously taxed income arising from redemption of CFC stock.
- Tax planning after the Small Business Job Protection Act.
- Proposed investment adjustment regulations: consolidated return regulations "delink" basis adjustments from E & P adjustments.
- Termination of retiree health benefits.
- Prior closing agreement subject to innocent spouse provisions.
- Continuity-of-interest requirement not affected by partnership's distribution of stock received in reorganization.
- Tax practice responsibilities: due diligence update.
- A day in the life of a tax adviser using Windows.
- Now is the time: converting a C corporation to an S corporation or LLC.
- Interest on residential property debt not deductible as investment interest.
- IRS allows deduction for severance payments after Sec. 338 election.
- Foreign tax credits: reducing eight categories to two.
- Measuring insolvency under sec. 108.
- An inside look at the arbitration and mediation programs.
- ISC tax issues.
- Evaluating career and life from a "7 habits" perspective.
- AICPA asks Congress to repeal the AMT.
- Pension plan loan was prohibited transaction.
- IRS issues guidance on losses from Ponzi schemes.
- Continued trend toward state related-party expense addback.
- Open account debt for S shareholders.
- Reporting of foreign gifts received by U.S. persons.
- Avoiding dividend treatment on distributions by liquidating.
- Recent developments estate planning.
- Understanding the "origin-of-the-claim" doctrine.
- Transactions subsequent to a "B" reorganization.
- Divorce and gain exclusion.
- QTP contributions by nonindividuals.
- Applying for a fiscal year under Sec. 444 when an S election is made.
- Tax Court denies an impermissible accounting method change.
- Modification to trust agreements to avoid 35% "built-in gain" excise tax for 1997.
- Organization costs and start-up costs amortized over 15 years.
- Structuring insurance contracts to qualify under Sec. 1033.
- Relief from international double taxation.
- Tax fraud and bankruptcy dischargeability.
- Passive activity credit flowchart.
- Notice 98-31 and guidance on involuntary method changes.
- Does Norwest expand INDOPCO's reach?
- Casualty loss allowed for water damage from washing machine.
- Tax Accounting.
- Decision support software for tax.
- Focus on tax avoidance leads to changes in foreign reporting requirements.
- U.S.-Switzerland protocol will allow handover of UBS account holder information.
- Congress's end game of catching wealthy expatriators.
- Final regs. for trust status as foreign or domestic.
- Individual taxation report.
- Treaty bars attribution of capital to U.K. bank's U.S. branch.
- Updates and guidance on key IRS practice developments.
- Tips and tricks for onboarding new clients.
- IRS sets rules for SLOB determination letters.
- Deferral of income from sale of gift cards.
- IRS cannot enforce summons.
- Taxation of outbound transfers of foreign goodwill or going concern value under secs. 367(a) and (d).
- Modifications of legal relationships can have Chapter 14 implications.
- Overpayments credited to estimated tax.
- Avoiding the pitfalls associated with attempts to recharacterize activities.
- Personal goodwill and the net investment income tax.
- Financing U.S. investments after the Revenue Reconciliation Act of 1993.
- Automatic relief for certain late S elections.
- Clarification.
- Cascading IRA beneficiaries.
- TaxTalent.
- Reflect, reboot, reengage: Emerging from busy season smarter and wiser.
- Current developments in S corporations.
- The long arm of the Canadian Goods and Services Tax.
- Qualified intermediary application process contains a number of surprises.
- When do foreign currency forward contracts constitute sec. 1256 contracts?
- Notice 2007-13: loosening the rules surrounding substantial assistance.
- Marriage equality: taxes, death, and everything in between.
- Captive insurance arrangement survives Tax Court scrutiny.
- Depreciating property following a like-kind exchange.
- Alternative approach for calculating loss disallowance on disposition or deconsolidation of subsidiary stock.
- Taxpayer denied exclusion for gain on the sale of a principal residence.
- Update on investment advisers regulation: the proposed IARD and compliance issues.
- Prop. regs. on mid-contract change in taxpayer under long-term contract method.
- Pro-taxpayer decision on claim-of-right relief.
- IRS provides guidance on perfecting S elections and QSub elections.
- The Handbook of Business Valuation and Intellectual Property Analysis.
- Mandatory electronic filing of partnership returns delayed.