Interpreting SEC Schedules 13D and 13G for Sec. 382 Purposes
Article:
Sec. 382 requires a taxpayer corporation to track the ownership shifts among “5% shareholders.”
Published on May 11, 2010
Uncertainty Governs Advance Trade Discounts
Article:
This article discusses conflicting court opinions and IRS guidance on advance trade discounts and the merits of treating them as purchase price adjustments instead of income or loans.
Published on May 10, 2010
Temp. Regs. Give Rules on e-Postcards for Exempt Organizations
Article:
The IRS has issued regulations (TD 9366) governing how certain tax-exempt organizations that are not currently required to file annual information returns will be required to submit an annual electronic notice.
Published on May 10, 2010
Temp. Regs. Expand IRS Offset Authority
Article:
The IRS has issued temporary regulations under Sec. 6411 relating to the computation and allowance of tentative carryback adjustments (i.e., tentative refunds).
Published on May 10, 2010
Substantial Risk of Forfeiture Under Sec. 457(f)
Article:
Sec. 457(f) deals with non qualified deferred compen sation (NQDC) plans of governmental and other tax-exempt employer sponsors. Specifically, Sec. 457(f) applies to plans classified as ineligible plans to distinguish them from Sec. 457(b) plans, which are called eligible plans.
Published on May 10, 2010
Substantial Compliance Insufficient to Allow Charitable Deduction
Article:
The Seventh Circuit has held that the doctrine of substantial compliance would not allow a trust to take a charitable deduction where the trustee had intended, but failed, to reform the trust as a charitable remainder unitrust.
Published on May 10, 2010
Special Issues Related to Distributions of Partnership Interests by Estates and Trusts
Article:
The complex rules governing the tax treatment of distributions from estates and trusts are further complicated when a partnership interest is distributed.
Published on May 10, 2010
Regulations Provide Guidance on Child and Dependent Care Credit
Article:
Sec. 21 was enacted to provide families with a tax benefit to help them stay in the workplace—a nonrefundable child and dependent care tax credit for employment-related expenses for the care of certain qualifying individuals.
Published on May 10, 2010
Recent Developments in Individual Taxation
Article:
This article covers recent significant developments affecting taxation of individuals, including cases, regulations, and legislative changes.
Published on May 10, 2010
Planning for Current Distributions from an LLC
Article:
LLC distributions most frequently occur when an LLC distributes operating cashflow or refinancing proceeds or liquidates a member’s interests. But distributions can also be used to accomplish the LLC’s tax planning goals.
Published on May 10, 2010
Late Legislation Affects AMT, Mortgage Foreclosures, FUTA
Article:
Congress passed several pieces of legislation that affecting 2007 tax returns.
Published on May 10, 2010
IRS Issues Reporting Requirement for Transactions of Interest
Article:
Practitioners should closely follow developments in the reportable transactions area to effectively respond to the identification of new TOIs. The first two have been issued, and others can be expected from time to time.
Published on May 10, 2010
IRS Announces Program to Share Employment Tax Exam Results with States
Article:
The IRS and 29 state workforce agencies jointly announced that they have entered into agreements to share with each other the results of employment tax examinations.
Published on May 10, 2010
Identifying Specified Employees Under Sec. 409A
Article:
Employers must understand how to determine whether an employee is a specified employee so that their nonqualified deferred compensation plan is operated in accordance with Sec. 409A.
Published on May 04, 2010
Final Regs. Provide Rules for Entities Required to File Electronically
Article:
The IRS issued final regulations on the requirements for electronically filing returns for corporations and other entities.
Published on May 04, 2010