New LB&I Knowledge Management Strategies IPGs and IPNs
Article:
Issue practice groups and international practice networks represent a new strategy the LB&I Division to pool and perpetuate institutional expertise.
Published on October 31, 2012
U.S. LLCs for U.K. Tax Purposes
Article:
What are the global tax implications for LLC members who are not U.S. residents?
Published on September 30, 2012
Final Regs. Issued on Entertainment Use of Business Aircraft
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The IRS issued final regulations relating to the disallowance under Sec. 274 of deductions for the use of business aircraft for entertainment (T.D. 9597).
Published on September 30, 2012
Taxpayer Cannot Revive Equitable Innocent Spouse Claim
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A U.S. District Court dismissed a taxpayer’s claim that she was entitled to innocent spouse relief under Notice 2011-70, which announced the removal of the two-year limitation period for claims for equitable innocent spouse relief under Sec. 6015(f).
Published on September 30, 2012
Prop. Regs. Clarify Who Is Subject to Limit on Meal and Entertainment Expenses
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The IRS released proposed regulations clarifying which party is subject to the rule that limits the deduction for meals and entertainment to 50% of the expenses incurred.
Published on September 30, 2012
Recent Developments in Estate Planning Part II
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This article covers recent developments in estate tax, including the portability election, proposed regs. on the alternate valuation date, FLPs.
Published on September 30, 2012
Model Intergovernmental FATCA Agreements Released Draft Form Posted
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The Treasury Department released a model intergovernmental agreement designed to implement the information-reporting and withholding-tax provisions of FATCA.
Published on September 30, 2012
IRS Permits Charitable Contributions to Single-Member LLCs
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The IRS explained that contributions to disregarded SMLLCs wholly owned and controlled by a U.S. charity will be treated as if made directly to the U.S. charity.
Published on September 30, 2012
Taxpayers Not Insolvent for Purposes of Sec. 108 Exclusion
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The Tax Court held that a married couple had failed to prove the FMV of their two homes and the husband’s pension and thus could not prove they were insolvent.
Published on September 30, 2012
Taxpayer Liable for Willful Violation of FBAR Requirements
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The Fourth Circuit held that a taxpayer had willfully violated the foreign bank account reporting requirements for two foreign bank accounts.
Published on September 30, 2012
LLC Distributions of Contributed Property
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An LLC member who makes a contribution to the LLC of property with an FMV different from its basis may be required to recognize gain or loss upon a subsequent distribution of the contributed property to another member.
Published on September 30, 2012
Watch for Further IRS Pronouncements on ITINs
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The AICPA has voiced concerns to the IRS about the Service’s interim rules that foreign nationals must generally include original documentation with Form W-7, Application for IRS Individual Taxpayer Identification Number.
Published on September 30, 2012
Current Developments in S Corporations
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During the period of this S corporation tax update, some major changes that directly affect S corporations took place. This article also presents tax planning ideas for S corporations and their shareholders.
Published on September 30, 2012
Setting Up Firm Procedures to Fight Identity Theft
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Ways tax professionals can help combat identity theft and educate their clients.
Published on September 30, 2012
How Changes in Corporate Tax Rate Can Affect Choice of C vs. S Corp.
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This item examines the effect of the proposed lower corporate tax rates in an analysis of the tax results of converting an S corporation to a C corporation.
Published on September 30, 2012