Timing Considerations of Discharging Taxes in a Chapter 7 Bankruptcy
Article:
This article discusses liquidations under Chapter 7 and focuses on individuals who are attempting to have their debts discharged, or wiped out, in bankruptcy.
Published on April 19, 2013
Circular 230 Its Day-to-Day Impact on Tax Practices
Article:
While discussions about Circular 230 usually focus on the standards it imposes relating to tax returns and opinions, the breadth and scope of Circular 230 also regulates the day-to-day business operations of tax practitioners relating to fees, client solicitations, marketing and advertising, and the management of client files and records.
Published on August 24, 2012
Tax Planning Opportunities for Funding an IRA
Article:
This article explores various funding choices for IRAs and provides an approach or model by which the tax adviser can optimize the funding choice, given the taxpayer’s tax-related goals.
Published on August 24, 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 August 24, 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 August 24, 2012
Different States Approaches on Sales Tax Treatment of Deal of the Day Instruments
Article:
Guidance on the sales tax treatment of prepaid discount vouchers or "deal of the day" certificates purchased on internet sites has been provided by several states recently, with more likely to follow soon.
Published on August 24, 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 August 24, 2012
Fourth Circuit Rejects Retroactive Accounting Method Change
Article:
The Fourth Circuit upheld a 2008 Tax Court decision that a company could not retroactively change its method of accounting for credit card late fees even though it was on an improper method.
Published on August 24, 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 August 24, 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 August 24, 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 August 24, 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 August 24, 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 August 24, 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 August 24, 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 August 24, 2012