The Tax Adviser June 2012 


    Section 530 Relief for Worker Classification Controversies
    Claire Nash

    A Road Map of Tax Consequences of Modifying Debt
    Howard Ro

    FATCA’s Withholding Requirements for Foreign Financial Institutions
    Philip Pasmanik

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    The Tax Adviser July 2012

    Publication Articles Taxing the Transfer of Debts Between Debtors and Creditors Edward J. Schnee and W. Eugene Seago Deducting Employee MBA Expenses Jos
    Published on September 16, 2013

    Using Sec. 338 to Avoid Anti-churning Rules

    Article When assets are sold in a taxable transaction, the buyer must be aware of limitations placed on amortizing certain acquired intangibles under the anti-churning rules; a recent ruling highlights the ability to use a Sec. 338 election to create the effect of an asset sale while avoiding the antichurning rules.
    Published on July 01, 2012

    Preparing for the Medical Device Excise Tax

    Article Taxpayers may face a number of unresolved issues in preparing to comply with the new excise tax on sales of medical devices.
    Published on July 01, 2012

    Increased Focus on International Activities of Tax-Exempt Organizations

    Article Many tax-exempt entities participate in the global economy by engaging in charitable or other exempt activities overseas and making foreign financial investments; These activities have drawn attention from the IRS as they examine the flow of tax-exempt funds around the world.
    Published on July 01, 2012

    FIRPTA Notice Requirements for Property Acquired in Foreclosure Sale

    Article Parties involved in the disposition of a U.S. real property interest as the result of a repossession of or foreclosure on the property need to be aware of their ) withholding requirements, as well as the availability of alternative withholding and notice requirements for foreclosure dispositions.
    Published on July 01, 2012

    Homeland Security May Contact U.S. Persons Living Abroad Who Owe Back Taxes

    Article The IRS has established procedures to facilitate tax collection from taxpayers who live outside the United States, including submitting identifying taxpayer information to a database maintained by the Department of Homeland Security.
    Published on July 01, 2012

    Contributing to a Childs IRA

    Article Establishing an IRA in a child’s name can be an effective planning technique for a child with earned income.
    Published on July 01, 2012

    Interaction of the Subpart F Dual-Character Property and Majority-Use Rules

    Article When a controlled foreign corporation (CFC) sells property used in its active business, any gain generally is not treated as subpart F income includible in its U.S. shareholders’ taxable income.
    Published on July 01, 2012

    Federal Income Tax Treatment of Certain Transferable State Tax Credits

    Article The emergence of online marketplaces and auction houses has provided a single point of contact for both sellers and buyers, making sales and purchases of transferable state tax credits more common.
    Published on July 01, 2012

    Global High-Wealth Audit Update

    Article While the IRS audit rate for individual returns of persons earning less than $200,000 has hovered at about 1% over the past several years, 12% of individual taxpayers with incomes of $1 million or more were audited in fiscal year 2011.
    Published on July 01, 2012

    The IRS Collection Process A Review of the Basics

    Article Practitioners should know the procedures the IRS follows in its collections process.
    Published on July 01, 2012

    Should Collection Due Process Hearings Be Recorded

    Article Collection due process (CDP) hearings, unlike many other administrative hearings, are not required to be, and often are not, recorded.
    Published on July 01, 2012

    Combined Reporting Creates Compliance Challenges

    Article An increasing number of states have enacted or proposed combined reporting requirements for related entities involved in a unitary business, creating increased compliance burdens for taxpayers and administrative challenges for state tax agencies.
    Published on July 01, 2012

    Post-Deal Depreciation Impact of Certain Nonrecognition Transactions

    Article When planning an incorporation or reorganization transaction, taxpayers and their advisers may not examine in depth the related accounting method and depreciation issues that arise as a result of the transaction.
    Published on July 01, 2012

    Sales Tax Audit Best Practices

    Article This article discusses common issues in state sales tax audits and gives tips and best practices for each part of an audit life cycle.
    Published on July 01, 2012

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