The Tax Adviser 2011 

     

     

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    Schedule UTP IRS Mandates Disclosure of Uncertain Tax Positions

    Article This article explores the requirements of Schedule UTP, discusses modifications to the IRS’s policy of restraint pertaining to tax reconciliation workpapers, and suggests how to avoid the inadvertent waiver of the work-product privilege for documents relating to uncertain tax positions.
    Published on April 02, 2014

    Schedule UTP IRS Mandates Disclosure of Uncertain Tax Positions

    Article This article explores the requirements of Schedule UTP, discusses modifications to the IRS’s policy of restraint pertaining to tax reconciliation workpapers, and suggests how to avoid the inadvertent waiver of the work-product privilege for documents relating to uncertain tax positions.
    Published on April 02, 2014

    False Tax Returns, Mail Fraud, and Money Laundering

    Article The Third Circuit Court of Appeals may have opened the door to a new approach that could result in significantly increased criminal penalties for taxpayers who file false returns. Taxpayers who mail or e-file their tax returns and knowingly understate their taxable income thereon may be exposing themselves to the
    Published on April 02, 2014

    False Tax Returns, Mail Fraud, and Money Laundering

    Article The Third Circuit Court of Appeals may have opened the door to a new approach that could result in significantly increased criminal penalties for taxpayers who file false returns. Taxpayers who mail or e-file their tax returns and knowingly understate their taxable income thereon may be exposing themselves to the
    Published on April 02, 2014

    When Is a U.S. LLC a Partnership for U.S. and U.K. Tax Purposes

    Article U.S. LLCs have become the preferred business entity in many situations because their members get both legal liability protection while being taxed in the United States as a partnership. This item examines how profits and losses of a U.S. LLC will be taxed on a U.K. resident’s U.K. tax return.
    Published on October 23, 2013

    When Is a U.S. LLC a Partnership for U.S. and U.K. Tax Purposes

    Article U.S. LLCs have become the preferred business entity in many situations because their members get both legal liability protection while being taxed in the United States as a partnership. This item examines how profits and losses of a U.S. LLC will be taxed on a U.K. resident’s U.K. tax return.
    Published on October 23, 2013

    Equity-Based and Nonqualified Deferred Compensation Plans

    Article This article provides an overview of the federal income taxation rules governing equity-based compensation plans as well as nonqualified deferred compensation plans.
    Published on October 22, 2013

    Equity-Based and Nonqualified Deferred Compensation Plans

    Article This article provides an overview of the federal income taxation rules governing equity-based compensation plans as well as nonqualified deferred compensation plans.
    Published on October 22, 2013

    100% Bonus Depreciation Guidance Issued

    Article In Rev. Proc. 2011-26, the IRS has issued guidance on how taxpayers can deduct 100% of the cost of qualified business property placed in service in 2011 under rules enacted last year .
    Published on August 06, 2013

    100% Bonus Depreciation Guidance Issued

    Article In Rev. Proc. 2011-26, the IRS has issued guidance on how taxpayers can deduct 100% of the cost of qualified business property placed in service in 2011 under rules enacted last year .
    Published on August 06, 2013

    Current Corporate Income Tax Developments, Part I - 2011

    Article Part I of this two-part article focuses on nexus, tax base, allocable/apportionable income, and Sec. 338(h)(10) transactions.
    Published on January 22, 2013

    Current Corporate Income Tax Developments, Part I - 2011

    Article Part I of this two-part article focuses on nexus, tax base, allocable/apportionable income, and Sec. 338(h)(10) transactions.
    Published on January 22, 2013

    Current Corporate Income Tax Developments (Part II) - 2011

    Article This article covers some of the more important developments in the areas of apportionment, unitary groups/filing methods, administration, flowthrough entities, and other significant corporate state tax issues.
    Published on January 08, 2013

    Current Corporate Income Tax Developments (Part II) - 2011

    Article This article covers some of the more important developments in the areas of apportionment, unitary groups/filing methods, administration, flowthrough entities, and other significant corporate state tax issues.
    Published on January 08, 2013

    Conflicts of Interest IRS Rules Differ from AICPA Professional Standards

    Article Circular 230 forbids federal tax practitioners from having conflicts of interest, defined as representation of one client that is directly adverse to that of another client, or representing a client in circumstances creating a significant risk that the representation of one or more clients will be materially limited by the
    Published on January 08, 2013

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