January

    The Tax Adviser January 2013 

    Photo by Hemera/Thinkstock Articles

    Key Aspects of the New Tangible Property Regulations
    Susan E. Anderson

    Judicial Deference to Regulations: Home Concrete & Supply, LLC
    Donald T. Williamson and Blair Staley

    Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part II)
    Lawrence H. McNamara Jr.

    Accounting Method Changes Under the Tangible Property Regulations 
    Jane Rohrs and Natalie Tucker

     

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    Accounting Method Changes Under the Tangible Property Regulations

    Article This article details the method change rules under the current automatic consent procedural guidance and discusses the method changes that would be necessary to early adopt provisions of the temporary regulations.
    Published on January 11, 2013

    Judicial Deference to Regulations Home Concrete & Supply, LLC

    Article This article reviews the Supreme Court opinions and IRS regulations that gave rise to Home Concrete and analyzes how a deeply divided Supreme Court resolved the issue.
    Published on January 01, 2013

    Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part II)

    Article This two-part article explains the computations, payment, and reporting requirements for U.S. trust and estate distributions to foreign beneficiaries.
    Published on January 01, 2013

    IRS Clarifies When Debt Instruments Are Publicly Traded

    Article The IRS issued final regulations clarifying the circumstances in which property is traded on an established market (i.e., publicly traded) for purposes of determining the issue price of a debt instrument.
    Published on January 01, 2013

    IRS Illustrates Employee Reimbursement Plans

    Article The IRS has described four situations where employers have recharacterized taxable wages as nontaxable business expense reimbursements and has ruled on whether these arrangements satisfy the business connection requirement of the accountable plan rules.
    Published on January 01, 2013

    LB&I Instructs on Insurance Companies Partial Worthlessness Deductions Under Sec. 166(a)(2)

    Article The IRS issued an Industry Director Directive addressing partial worthlessness deductions under Sec. 166(a)(2) taken by insurance companies for eligible loans.
    Published on January 01, 2013

    IRS Makes Tax Exempt/Government Entities Fast Track Settlement Program Permanent

    Article The IRS announced it is making the Tax Exempt and Government Entities Division Fast Track Settlement (TE/GE FTS) program permanent.
    Published on January 01, 2013

    Intangible Drilling Cost Preference Exception Not Available When AMTI Is Negative

    Article In CCA 201235010, the IRS determined that the intangible drilling cost preference exception may not be used in tax years when the taxpayer has negative alternative minimum taxable income.
    Published on January 01, 2013

    State Law Property Classifications Do Not Control Like Kind Determination

    Article The IRS ruled that state law property classification does not control whether exchanged properties are considered of “like kind” for purposes of Sec. 1031.
    Published on January 01, 2013

    IRS Issues Prop. Regs. on Allocation of Costs Under Simplified Sec. 263A Methods

    Article The IRS has issued proposed regulations on allocating costs to property produced or acquired by a taxpayer for resale.
    Published on January 01, 2013

    Regs. Issued on Integrated Hedging Transactions of Qualifying Debt

    Article The IRS published regulations addressing certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions.
    Published on January 01, 2013

    Prop. Regs. Expand Options for Private Foundations in Grant-Making Process

    Article The IRS proposed expanding the types of tax professionals on which private foundations may rely when making good-faith determinations as to the public charity status of foreign grantees.
    Published on January 01, 2013

    Contract With Related For-Profit Entity Disqualifies Exemption

    Article The IRS ruled that an organization founded to facilitate charitable donations through a website and mobile phone application failed to establish that it operated exclusively for exempt purposes.
    Published on January 01, 2013

    IRS Issues Guidance on Corporate Equity Reduction Transactions

    Article The IRS published the first guidance addressing corporate equity reduction transactions since the CERT rules were enacted in 1989.
    Published on January 01, 2013

    IRS Offers Guidance on Accounting for Black Liquor Credit Repayments

    Article The IRS Chief Counsel’s Office addressed under what circumstances interest must accompany a repayment of the alternative fuel mixture credit received and during what year taxpayers converting the AFMC into the cellulosic biofuel producer credit should include that credit in income under Sec. 87.
    Published on January 01, 2013

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