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Table of Contents
December 2006

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 ªcovered opinionª 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
  * The Bad-Debt Reserve: Opportunity for Partial Current Deduction
 
Charitable Contributions
    Substantiation Rules for Charitable Gifts by Tim Krumwiede and Larry Witner
 
Corporations & Shareholders
    Planning Techniques to Avoid the Reclassification of Shareholder Debt as Equity by Linda Burilovich
 
Employee Benefits & Pensions
    Sec. 409A’s Application Deferred
  * Stock Options and SEC Section 16(b)
 
Estates, Trusts & Gifts
  * Form over Substance: District Court Denies Split-Interest Charitable Deduction
    Second Circuit Holds Trust Investment Advisory Fees Subject to 2% Floor
 
Foreign Income & Taxpayers
  Dual Consolidated Losses
  * IRS Issues Additional Guidance on Sec. 7874 Inversions
  The Post-TIPRA Foreign Earned Income and Housing Exclusions for Individuals by Howard Godfrey and Neil A.J. Sullivan
 
Gains & Losses
    Sale of Lottery Payments Produces Ordinary Income
 
Gross Income
  * Tax on Emotional Damages Held Unconstitutional: How to Protect Clients in the Short Term
 
Individuals
    AICPA Launches Financial Literacy Ad Campaign
  * IRA Distributions to Charities
    IRS Issues Guidance on Qualifying Child Tie-Breaking Rule
  * Service Clarifies Position on Employer Payments to Relocation Service Companies
 
Practice Management
    Security Issues when Using Outside Networks
 
Procedure & Administration
    AICPA Requests PPA ’06 Technical Correction Suggestions
    IVES Program
    Late Extension Waiver Was Valid
 
 S Corporations
    Determining Eligibility to Elect QSub Status
  * Twist to a QSST Presents a Trap
 
 State & Local Taxes
    Streamlined Sales Tax: Debate Continues on MPU Purchases and the Digital Goods Definition
  * The Future of E-Commerce Tax Liability
Reader Survey

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