October

    The Tax Adviser October 2012 

    Articles

    New LB&I Knowledge Management Strategies: IPGs and IPNs
    Robert D. Adams

    Current Developments in S Corporations
    Stewart S. Karlinsky and Hughlene Burton

    U.S. LLCs for U.K. Tax Purposes
    Rob Whittall

    Recent Developments in Estate Planning: Part II
    Justin P. Ransome and Frances Schafer

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    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 24, 2014

    Recent Developments in Estate Planning Part II

    Article This article covers recent developments in estate tax, including the portability election, proposed regs. on the alternate valuation date, FLPs.
    Published on September 24, 2014

    Alternative Apportionment Tough for the Taxpayer, (Too) Easy for the States

    Article Alternative apportionment provisions aim to provide limited relief through the possibility of “opting out” of the standard apportionment formulas when their application would produce particularly inequitable results.
    Published on September 24, 2014

    Planning for Redemptions of S Corporation Stock Using Contingent Payments

    Article When shareholders of an S corporation choose to part ways, they often do so by redeeming a departing shareholder’s stock.
    Published on September 24, 2014

    Inadvertent S Corp. Terminations

    Article When an S election is made, requirements must be met to avoid an inadvertent termination of S status.
    Published on September 24, 2014

    QEF Elections Under PFIC Rules

    Article In enacting the PFIC rules in 1986, Congress created a complex and punitive tax regime for certain passive foreign investments that continues to plague U.S. taxpayers and their tax advisers.
    Published on September 24, 2014

    The Partnership Technical Termination Trap

    Article A sale or exchange of 50% or more of the total interest in a partnership’s capital and profits within a 12-month period causes the tax year of the partnership to close.
    Published on September 24, 2014

    Ponzi Schemes, Clawbacks, and the Claim of Right Doctrine

    Article Many people who lost money in Ponzi schemes are later told by a bankruptcy trustee that they were “net winners” and are required to pay back past withdrawals to be redistributed to the larger pool of victims.
    Published on September 24, 2014

    Timing a Loss Deduction

    Article When a real estate venture is structured so that one partner provides the capital and the second provides operational experience, how are losses incurred by the capital partner treated?
    Published on September 24, 2014

    Potential U.S. Tax Consequences of Using Foreign Sales or Manufacturing Branches

    Article The IRS late last year released final regulations on the rules for foreign base company sales income (FBCSI) under Sec. 954(a)(2) and Regs. Sec. 1.954-3(b).
    Published on September 24, 2014

    IRS Issues Blueprint for IC-DISC Audits

    Article The IRS released its advanced audit guide for agents involved in examinations of IC-DISCs.
    Published on September 24, 2014

    Formula Marital Deduction Clause Not a Guaranteed Estate Tax Shelter

    Article The Turner cases highlight the importance of properly transferring FLP interests during life in a way that avoids the trap of creating an estate tax when the decedent planned to have none.
    Published on September 24, 2014

    Depreciation and Changes in Use of Real Property

    Article This item discusses the distinction between residential and nonresidential property, depreciation, and the application of the change-in-use regulations if a rental property changes from residential use to nonresidential or vice versa.
    Published on September 24, 2014

    How Changes in Corporate Tax Rate Can Affect Choice of C vs. S Corp.

    Article 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 24, 2014

    Payments to Related Entities Are Dividends, Fail Independent-Investor Test

    Article The Seventh Circuit held that a C corporation’s payments to entities owned by its shareholders for consulting services were disguised dividends.
    Published on September 24, 2014

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