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June

The Tax Adviser June 2012 

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Nonaccrual-Experience Book Safe-Harbor Method

Article Taxpayers generating revenues from services may now be able to use the nonaccrual-experience book safe-harbor method to exclude qualifying uncollectible revenues from taxable income.
Published on July 02, 2012

The Tax Adviser June 2012

Publication Articles Section 530 Relief for Worker Classification Controversies Claire Nash A Road Map of Tax Consequences of Modifying Debt How
Published on July 01, 2012

A Road Map of Tax Consequences of Modifying Debt

Article As a result of the recession, many borrowers are “underwater” on their loans (the property is worth less than the loan balance). This has led to a substantial increase in debt restructuring activity.
Published on June 01, 2012

Recurring-Item Exception Can Economic Performance Be Accelerated

Article Rev. Rul. 2012-1 addresses the application of the economic performance rules and whether the recurring-item exception may be applied to accelerate economic performance with respect to liabilities for the lease of equipment and a related maintenance agreement.
Published on May 31, 2012

Who Is a Limited Partner The IRS Issues Sec. 469 Prop. Regs.

Article Despite its importance in assessing an individual’s tax liability, the determination of whether a person is a “limited partner” for federal income tax purposes is often uncertain.
Published on May 31, 2012

Accounting for Customer Loyalty Programs Opportunities and Pitfalls

Article An often overlooked regulation may offer substantial benefits with respect to the treatment of redemption costs for taxpayers with loyalty programs.
Published on May 31, 2012

Multistate Partnerships To Withhold, or Not to Withhold

Article The varying rules for withholding can create a compliance nightmare for multistate partnerships with a large number of partners.
Published on May 31, 2012

Golden Parachute Calculations 10 Misunderstood Aspects of Secs. 280G and 4999

Article When a company experiences a change in control, the golden parachute rules are intended to discourage excessive compensation for “disqualified individuals” by imposing adverse tax consequences on both the company and the disqualified individuals.
Published on May 31, 2012

Lifetime Tax Planning for LLC Owners

Article Several steps can be taken before a LLC member’s death to reduce estate and income taxes and to plan for an orderly succession.
Published on May 31, 2012

IRS Withholding Tax Enforcement Dropping the Other Shoe

Article Despite a hefty price for noncompliance—including secondary liability for the withholding tax, interest, and various penalties—U.S. companies have yet to master the science of cross-border withholding.
Published on May 31, 2012

Key Planning Considerations for Cash Flow in Retirement

Article Assuring sufficient cash flow during retirement is a critical planning consideration. This column addresses various factors that affect cash flow for retirees in the current economic climate.
Published on May 31, 2012

Sidestepping Deferred Intercompany Gain

Article This item illustrates how transfers of items outside a U.S. consolidated group can trigger a deferred intercompany gain and suggests ways to avoid that result in certain situations.
Published on May 31, 2012

Mailbox Rule Does Not Apply Where Taxpayer Cannot Prove Mailing

Article The First Circuit dismissed a suit for refund of Federal Insurance Contributions Act (FICA) taxes Maine Medical Center mistakenly paid for its medical residents in the 2001 tax year.
Published on May 31, 2012

FATCAs Withholding Requirements for Foreign Financial Institutions

Article FATCA imposes rigid new account identification, reporting, and tax withholding requirements on foreign financial institutions and other withholding agents.
Published on May 31, 2012

Priority Phone Service Created for Correspondence Audits

Article The IRS has launched a new toll-free phone service for tax professionals to use when responding to correspondence examination telephone calls or letters.
Published on May 31, 2012

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