The Tax Adviser June 2009 

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    The Tax Adviser June 2009

    Published on April 29, 2010

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

    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 June 01, 2009

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