Current Developments in Partners and Partnerships
Article :
This article reviews and analyzes recent rulings and decisions involving partnerships.
Published on January 31, 2012
Integrating Circular 230 into the Tax Curriculum
Article :
Circular 230 is crucial to tax education because it forms the ethical standards of tax practice. Students who plan to become tax practitioners must become well acquainted with Circular 230 along with the underlying laws and regulations governing tax practice.
Published on January 31, 2012
Final Hot Stock Regs. and Dunn Trust
Article :
In October, Treasury issued final regulations that deal with the application of the Sec. 355(a)(3)(B) “hot stock” rule (T.D. 9548).
Published on January 31, 2012
Integrating Circular 230 into the Tax Curriculum Appendix
Exhibit :
This appendix provides a more detailed suggested solution to the five questions presented in the Feb. 2012 Campus to Clients column.
Published on January 31, 2012
Determining the LLCs Required Year
Article :
An LLC taxed as a C corporation can choose any year end as the tax year end; if an LLC is classified as a partnership for federal income tax purposes, however, its tax year is governed by Sec. 706(b).
Published on January 31, 2012
Proposed Sec. 382 Regs. Simplify Small Shareholder Treatment
Article :
Sec. 382 and the regulations thereunder rank among some of the most complex, nonintuitive rules in federal tax law, all aimed at curbing the practice of trafficking in NOLs, or other loss attributes, in a corporation.
Published on January 31, 2012
Losses Related to an Insolvent Corporation
Article :
The IRS issued a general legal advice memorandum that addressed the tax consequences when an insolvent foreign subsidiary of a domestic U.S. corporation elected to be classified as a partnership.
Published on January 31, 2012
Prop. Regs. Require NUBIG and NUBIL Redetermination for Consolidated Sec. 382 Purposes
Article :
The IRS recently proposed revisions to the consolidated return regulations on the application of Sec. 382 and calculation of net unrealized built-in gains and losses.
Published on January 31, 2012
Tax Court Rules Notice Not Required for Crummey Powers
Article :
In Turner, the Tax Court ruled that actual notice of a benficiary's Crummey withdrawal right is not required to satisfy the present-interest requirement for the gift tax annual exclusion.
Published on January 31, 2012
IRS Launches Worker Classification Settlement Program
Article :
The IRS unveiled a program that allows taxpayers to voluntarily reclassify independent contractors as employees and pay significantly reduced prior employment taxes, with no penalties or interest.
Published on January 31, 2012
The Dual Consolidated Loss Quandary
Article :
The rules and regulations pertaining to dual consolidated losses are very complex; practitioners should always be diligent and aware of possible DCL scenarios.
Published on January 31, 2012
States Battle for R&D Investment by Enhancing Tax Incentives
Article :
When evaluating the potential tax effect of research and development investments, taxpayers should be aware of the generous tax incentives offered by many states that can add to the benefit received for the federal R&D credit.
Published on January 31, 2012
Invalid Sec. 754 Elections Some Observations
Article :
This item discusses the requirements for a valid Sec. 754 election and then highlights some of the reasons for those late or missed elections.
Published on January 31, 2012
Proposed Regs. Relating to the Retail-Inventory Method
Article :
The IRS issued proposed regulations relating to the retail-inventory method of accounting.
Published on January 31, 2012
Increased Focus on and Potential Ramifications of R&E Expenditures
Article :
Many taxpayers may have noticed a recent increased IRS focus on R&E expenditures. As a result of this increased focus, it is time for taxpayers to increase their focus as well.
Published on January 31, 2012