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Table of Contents
July 2007

Note: In accordance with IRS Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers before the Internal Revenue Service, the information on this website is not intended or written to be used as, and cannot be used as or considered to be a "covered opinion" or other written tax advice, and should not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute or other purposes.
Asterisks indicate items in the Tax Clinic department.
 

Accounting Methods & Periods

  * Is a Change in Characterization an Accounting-Method Change?
 

Consolidated Returns

  * Professional Corporations: To Be or Not to Be a Member of a Consolidated Group
 

Corporations & Shareholders

  *

Applying the Rescission Doctrine

 

Depreciation

    GO Zone Depreciation
 

Employee Benefits & Pensions

    IRS Issues Final Rules on Nonqualified Deferred Compensation
 

Planning for Distributions of Employer Securities      

 

Estates, Trusts & Gifts

 

Teaching an Old Dog New Tricks: CRTs and UBTI   

  Allocating Partnership Depreciation between Trusts and Beneficiaries by Justin P. Ransome
  Nonspouse Beneficiary Meets PPA ’06 Rollover Requirements
 

Foreign Income & Taxpayers

  *

Hybrid Financing Structures

  * Increased Compliance Burden under New Sec. 987 Prop. Regs.
  * Out of the Ordinary: Capital Gain/Loss from the Sale of a Foreign Currency-Denominated Debt Instrument
    Choice of Entity for Expansion of Operations into a Foreign Country by Howard Godfrey, Jack M. Cathey and Robert Verzi
 

Gains & Losses

  * Rulings Relax Related-Party Exchange Rules
 

Gross Income

  *

Sec. 199 Final Regs. Affect Online Software and Advertising

 

Personal Financial Planning

    When to Begin Receiving Social Security Benefits
 

Practice & Procedures

   

IRS Launches New Industry Issue Focus Strategy

    Some Schedule K-1 Recipients Get Reportable Transaction Disclosure Relief
   

IRS Increases Correspondence Exam Coverage

   

The Power of Gifting

 

Procedure & Administration

   

Circular 230 Penalty

  * Allocating Advance Payments between Tax and Interest
    Taxpayer Liable for Taxes Misappropriated by Payroll Services Firm
 

Special Industries

  * Evolution of Commodity-Linked Investments by Mutual Funds
    Service-Warranty Companies—the Hybrid of the Insurance Industry by Michelle Bertolini and Sharon S. Lassar
 

Special Feature

  * Web Browsing
 
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