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November

The Tax Adviser November 2012 

Articles

Advising Nonresidents and Recent U.S. Residents on Estate Tax Issues
Michael L. Moore

Compensation and Benefits Update: Retirement Plans and Executive Compensation
Deborah Walker and Thomas R. Pevarnik

Apportionment Using Market-Based Sourcing Rules: A State-by-State Review
Michael S. Schadewald

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Compensation and Benefits Update Retirement Plans and Executive Compensation

Article This article focuses on recent changes affecting qualified retirement plans and executive compensation.
Published on March 18, 2013

Advising Nonresidents and Recent U.S. Residents on Estate Tax Issues

Article Understanding the intricacies of residency and domicile is necessary to understand what will be included in a decedent’s estate for U.S. estate tax purposes.
Published on November 14, 2012

IRS to Allow Automatic Accounting Method Changes in Corporate Reorganizations

Article The IRS announced a change in its policy on automatic accounting method changes in corporate reorganizations.
Published on November 13, 2012

Apportionment Using Market-Based Sourcing Rules A State-by-State Review

Article This article discusses issues in applying market-based sourcing rules and looks at how those rules work in the states that have adopted them.
Published on October 31, 2012

Tax Practice Quality Control

Article Practitioners should consider implementing a tax practice quality-control system.
Published on October 31, 2012

Employee Expense Reimbursement Arrangement Guidance Issued

Article The IRS issued guidance on employee reimbursements and whether they satisfy the business connection and other requirements to be treated as paid under an accountable plan under.
Published on October 31, 2012

Controlled Groups and Deductibility of Patronage Dividends

Article CCA 201228035 addresses specifically the tax treatment of patronage dividends among related parties and/or controlled groups.
Published on October 31, 2012

IRS Modifies Position on Frozen Refundable Credits and the Substantial Understatement Penalty

Article The IRS announced that it will no longer impose a substantial understatement penalty when a taxpayer claims a refundable tax credit he or she is not entitled to, but the IRS does not pay the refund or approve the credit.
Published on October 31, 2012

Allocation of Sec. 263A Costs Addressed in Prop. Regs.

Article The IRS issued proposed regulations that affect taxpayers who produce or resell property and allocate costs under the simplified production method or simplified resale method.
Published on October 31, 2012

Taxpayer Advocate Service Will No Longer Accept Certain Cases

Article The Taxpayer Advocate Service changed its criteria for accepting individual taxpayer cases for assistance, reducing the instances in which it will accept cases.
Published on October 31, 2012

Treatment of Identity Theft Returns Clarified

Article The IRS Office of Chief Counsel explained what the IRS can do when a return is filed by an identity thief and the IRS has issued a statutory notice of deficiency based on that fraudulent return.
Published on October 31, 2012

R&E Credit Opportunities for the Construction Industry

Article Taxpayers in the construction industry may want to consider the Sec. 41 research credit.
Published on October 31, 2012

Proposed Amendments to Article IV of the Multistate Tax Compact

Article The Multistate Tax Commission is considering significant changes to the rules that govern how multistate businesses are taxed.
Published on October 31, 2012

Consequences of Not Filing Go Beyond the Nonfiling Penalty

Article The Tax Court denied a deduction for a claimed theft loss because the taxpayer had not filed a tax return for the year of loss and thus did not make a proper election to itemize deductions.
Published on October 31, 2012

Prop. Regs. Limit Conditions Resulting in Substantial Risk of Forfeiture Under Sec. 83

Article The IRS issued proposed regulations (REG-141075-09) to clarify specifically which conditions result in a substantial risk of forfeiture under Sec. 83.
Published on October 31, 2012

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