The Tax Consequences of Point-Based Employee Reward Programs

Article:  This article explores the tax consequences of point-based employee recognition programs.
Published on July 13, 2012

Significant Recent Corporate Developments

Article:  This article summarizes selected recent developments in federal income taxation of corporations and shareholders.
Published on February 03, 2011

Is There Still Time to Correct IRS Interest Mistakes

Article:  If the IRS does not refund the correct interest, what is the statute of limitation for a claim for additional interest? What is statute of limitation for a claim for refund for interest netting and how long the IRS has to assess the correct amount of deficiency interest? The answers
Published on January 28, 2011

IRS Releases Procedures Allowing Appeals Review of International Penalties Prior to Payment

Article:  The IRS has made it a priority to improve voluntary compliance with the international tax provisions and to reduce the tax gap attributable to international transactions. This focus on international compliance has led to increased enforcement of international information-reporting requirements and the associated penalties.
Published on January 28, 2011

Record Retention Policies How Long Is Long Enough

Article:  In advising clients on retention policies, the concern is often with keeping records too long, and because of the cost and logistical issues related to record retention, many taxpayers want to destroy outdated records as soon as possible. However, holding onto records can be beneficial, as illustrated by a recent
Published on January 28, 2011

Cost-Sharing Agreements and the Arms-Length Standard

Article:  The Xilinx case has created turmoil in the international tax community for quite some time, and there is no clear end in sight. Although the Ninth Circuit reversed its controversial decision, uncertainty surrounds the validity of Treasury’s new regulations explicitly requiring that cost sharing include stock options.
Published on January 28, 2011

REITs Data Center Buildings Constitute Qualifying Real Property

Article:  The IRS ruled that apparent “data center” buildings, including their structural components, constitute real property for purposes of the REIT asset and income tests and that services furnished in connection with leasing space in the buildings will not cause any amounts received from tenants to be treated as other than
Published on January 28, 2011

Prop. Regs. Would Eliminate Paper Coupons for Federal Tax Deposits

Article:  The IRS has issued proposed regulations that, effective in 2011, would eliminate the option of making federal tax deposits by paper coupon. Going forward, taxpayers must submit all federal tax deposits using the Electronic Federal Tax Payment System (EFTPS).
Published on January 28, 2011

Form W-2 Reporting Requirement Extended for Employer-Sponsored Group Health Plans

Article:  The IRS announced that employers will not be required to report the cost of employer-sponsored coverage on Forms W-2, Wage and Tax Statement, issued for 2011, due to the difficulty in preparing payroll systems for the requirement.
Published on January 28, 2011

Check-the-Box Relief for Certain Foreign Entities Electing Flowthrough Treatment

Article:  The IRS provided relief to certain foreign eligible entities that made erroneous entity classification elections (check-the-box elections) based on a mistaken understanding of the number of owners as of the effective date of the election.
Published on January 28, 2011

IRS Introduces Final Schedule UTP with Modifications

Article:  The issuance of a final schedule and instructions makes it important for companies with assets of $100 million or more that issue audited financial statements to prepare for filing the Schedule UTP with their 2010 tax returns.
Published on January 28, 2011

IRS Issues Prop. Regs. on Series LLCs and Cell Companies

Article:  Proposed regulations would treat, for federal tax purposes, a series of a domestic series limited liability company (LLC), a cell of a domestic cell company, and a foreign series or cell that conducts an insurance business as an entity formed under local law, regardless of whether the entity is treated
Published on January 28, 2011

IRS Will Not Challenge OID Treatment of Interchange Fees

Article:  The IRS announced that it will no longer challenge whether interchange fee income earned by credit card issuers creates or increases original issue discount (OID) on a pool of credit card loans.
Published on January 28, 2011

IRS Guidance on FSA and HSA Reimbursements for OTC Drugs

Article:  The IRS has issued guidance implementing the Patient Protection and Affordable Care Act’s prohibition on reimbursement of the cost of over-the-counter drugs by HSAs, HRAs, Archer MSAs, and FSAs, which allows reimbursement for an OTC drug only if the individual has a prescription for the drug.
Published on January 28, 2011

IRS Revises Interim Guidance on Production Tax Credit for Refined Coal

Article:  In Notice 2010-54, the IRS modifies the definition of refined coal, allows certain processing of utility-grade coal to be taken into account for determining emissions reductions, and revises testing protocols.
Published on January 28, 2011