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June

The Tax Adviser June 2009 

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Legislation Extends Aviation Taxes

Article The Federal Aviation Administration Extension Act of 2009. This act extends the taxes that fund the Airport and Airway Trust Fund through the end of September.
Published on January 28, 2011

FBAR Penalties Reduced for Six Months

Article The IRS has provided a framework for voluntary disclosure requests containing offshore issues, such as previously undisclosed foreign financial accounts and entities.
Published on January 28, 2011

Prop. Regs. on Determining Partners Distributive Shares

Article The IRS has issued proposed regulations on determining partners' distributive shares of partnership items of income, gain, loss, deduction, and credit when a partner's interest varies during a partnership tax year.
Published on January 28, 2011

IRS Reverses Position on Eligibility of Intangibles for Like-Kind Exchange Treatment

Article The IRS Office of Chief Counsel has announced a change in its position on the use of certain intangible property in Sec. 1031 like-kind exchanges.
Published on January 28, 2011

IRS Advises How Part Owners Should Handle $1 Million Mortgage Deduction Limit

Article The IRS Office of Chief Counsel has issued a memorandum outlining how partial owners of a principal residence with a mortgage larger than $1 million should handle their mortgage deduction.
Published on January 28, 2011

Sec. 382 After the Bailout

Article Treasury issued several notices as part of the government's response to the economic crisis. The notices allow relief from Sec. 382 for loss corporations acquired under TARP. They also provide relief for obligations and other securities issued by Fannie Mae and Freddie Mac in the recent bailout.
Published on January 28, 2011

Student Loan Forgiveness and Repayment Programs

Article To provide a roadmap for these students and their tax advisers, this article describes the more prevalent loan forgiveness and loan repayment programs, along with the associated tax consequences.
Published on January 28, 2011

Tax Practice Quality Control Guide

Article The AICPA has provided substantial guidance to practitioners over the years on quality control as well as guidance regarding tax practice reviews, which are an integral part of the quality control process. It is important that all members of the firm (partners and employees) understand the firm's commitment to the
Published on January 28, 2011

Why and How to Conduct a Tax Practice Inspection

Article A firm can use a tax practice inspection as a tool to test the quality of tax services provided to clients, to develop specific recommendations for improvement, and to prepare or update a tax services policies and procedures manual.
Published on January 28, 2011

Handling LLC Member and Member Affiliate Loans and Guarantees

Article Special rules apply for allocating basis from loans made or guaranteed by limited liability company (LLC) members or affiliates of members.
Published on January 28, 2011

Establishing Substantial Authority for Undisclosed Tax Positions

Article To avoid the imposition of a penalty for an understatement related to an undisclosed position, a practioner must meet the substantial authority standard with respect to the position.
Published on January 28, 2011

Tax Amnesty Programs and Voluntary Compliance Initiatives A Way to Mitigate Declining State Revenues

Article Since 2000, more than half of the states have offered tax amnesty programs one or more times.
Published on January 28, 2011

Circular Like-Kind Exchange Disallowed

Article The Tax Court disallowed tax-free treatment for a like-kind exchange transaction in which the taxpayer exchanged properties with a related entity.
Published on January 28, 2011

Limitation Period for Equitable Innocent Spouse Relief Held Invalid

Article In a decision of the full court, the Tax Court held that Regs. Sec. 1.6015-5(b) (1), which imposes a two-year limitation period for requesting equitable innocent spouse relief, is an invalid interpretation of Sec. 6015(f).
Published on January 28, 2011

Recent Amendment to Sec. 1374 Provides Limited Opportunity for S Corps.

Article An amendment to Sec. 1374(d) provides a temporary exemption from the application of Sec. 1374 to sales of assets in 2009 and 2010, but only for S corporations that meet certain requirements.
Published on January 28, 2011

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