The Proper Timing of Workers Compensation Deductions

Article:  For companies with more than a de minimis amount in their workers’ compensation reserve, it may be worthwhile to review the details underlying the reserve amount.
Published on January 28, 2011

NOL Carryback Claims Can Unlock Closed Statute of LimitationYears

Article:  With the introduction of the five-year net operating loss (NOL) carryback in Sec. 172(h) as part of the Worker, Homeownership, and Business Assistance Act of 2009, taxpayers should consider the impact that carrying back an NOL has on the assessment statute of limitation.
Published on January 28, 2011

Notice 2010-6 Sec. 409A Document Failure Correction Program

Article:  The IRS has provided methods for taxpayers to voluntarily correct certain types of failures to comply with the document requirements of Sec. 409A.
Published on January 28, 2011

Growing Opportunities The Agricultural Chemical Security Credit

Article:  Taxpayers that deal with fertilizers and pesticides should consider their own facts and circumstances to determine how the agricultural chemical security credit might apply.
Published on January 28, 2011

Final Regs. on Cash D Reorgs.

Article:  The IRS published final regulations addressing the qualification and treatment of certain acquisitive transactions as reorganizations under Sec. 368(a)(1)(D) where no stock or securities of the acquiring corporation are issued in the transaction (cash D reorganizations).
Published on January 28, 2011

Tax Court Does Not Have Jurisdiction to Redetermine Sec. 6707A Penalties

Article:  The Tax Court held that it did not have jurisdiction to redetermine a taxpayer’s liability for Sec. 6707A penalties for failure to report involvement in a listed transaction.
Published on January 28, 2011

IRS Issues Regs. and Guidance on Disclosure of Tax Return Information

Article:  The IRS has issued regulations under Sec. 7216 that increase the circumstances in which tax return preparers can disclose or use certain limited tax return information and two revenue rulings that provide guidance to tax return preparers on situations in which they will not be liable for civil or criminal
Published on January 28, 2011

IRS Plans to Require Disclosure of UncertainTax Positions

Article:  The IRS said it is developing a schedule that certain businesses would be required to use to disclose uncertain tax positions on their returns annually.
Published on January 28, 2011

Gift Tax Paid onTransfer of QTIP Remainder Included in Estate

Article:  The Tax Court held that the amounts of gift tax paid by the recipients of a QTIP remainder are includible in the transferor’s gross estate under Sec. 2035(b).
Published on January 28, 2011

The Smartphone The Tax Practitioners Portable Office

Article:  Practioners can work more efficiently through mobile access to an office with a smartphone.
Published on January 28, 2011

IRS Announces Mandatory Registration,Testing, and CPE for Return Preparers

Article:  The IRS announced plans to require all return preparers to register with the IRS and to require unenrolled preparers to pass a competency exam and meet continuing professional education (CPE) requirements.
Published on January 28, 2011

Individual Taxation Digest of Recent Developments

Article:  This article covers recent significant developments affecting taxation of individuals, including legislative changes, cases, regulations, and other IRS guidance.
Published on January 28, 2011

Obtaining Tax Benefits with Health Savings Accounts

Article:  The Medicare Prescription drug and Modernization Act established health savings accounts (HSAs), which are aimed primarily at self-employed taxpayers, small business owners, and employees of small to medium-sized firms. Eligible individuals can make tax-deductible contributions into HSA accounts. The earnings inside the HSA are free from federal income tax, and
Published on January 28, 2011

The IRS Whistleblower Program

Article:  The IRS’s new whistleblower program and the efforts to publicize it have already generated many new claims. Given the significant awards that are now available under the program, the number of claims is likely to increase, making it important for practitioners to be familiar with the program and its rules
Published on January 28, 2011

Improved Education Credit Opportunities for High-IncomeTaxpayers

Article:  For 2009 and 2010, the American opportunity tax credit provides increased credit amounts for higher education expenses. This article discusses how taxpayers can best take advantage of the credit.
Published on January 28, 2011