October

    The Tax Adviser October 2009 

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    Indefinite-Lived Assets in Tax Provision

    Article Indefinite-lived assets can cause unexpected results related to the determination of a valuation allowance and its impact on the effective tax rate.
    Published on January 28, 2011

    New York Eliminates Temporary Stay Residency Exception

    Article New York is very aggressive in making sure that those who work or live in the state pay their fair share of taxes. Because falling under the definition of a New York resident can be very expensive, it is extremely important to understand the rules.
    Published on January 28, 2011

    Interest-Free Period Under Sec. 6601(c)

    Article The IRS recently provided some guidance on when underpayment interest is suspended under Sec. 6601(c).
    Published on January 28, 2011

    The National Taxpayer Advocates Annual Report to Congress (Part II)

    Article This item outlines the recommendations of Nina Olson, the national taxpayer advocate, for legislative reforms to the Code as presented in her annual report to Congress.
    Published on January 28, 2011

    Current Developments in S Corporations (Part I)

    Article This two-part article discusses recent legislation, cases, rulings, regulations, and other developments in the S corporation area. Part I covers operational issues; part II, in the November issue, will cover S corporation eligibility, elections, and termination issues.
    Published on January 28, 2011

    Tax Accrual Workpapers Not Protected by Work-Product Privilege

    Article Sitting en banc, the First Circuit reversed the ruling of a panel of the court and held that a corporation’s tax accrual workpapers were not protected from an IRS summons by the work-product privilege.
    Published on January 28, 2011

    Changes to Estimated Tax Payment Requirements

    Article For 2009 tax years, the American Recovery and Reinvestment Act instituted changes to the rules governing the amount of estimated tax that individual taxpayers with income from small businesses must pay.
    Published on January 28, 2011

    IRS Practice and Procedures Committee Update

    Article The IRS Practice and Procedures Committee held its semiannual meeting with executives of the Internal Revenue Service at the AICPA offices in Washington, DC, on May 18 and 19, 2009.
    Published on January 28, 2011

    Estimates and the Cohan Rule

    Article When dealing with clients who have incomplete records, return preparers are frequently forced to use estimates whether they want to or not.
    Published on January 28, 2011

    Making the Most of Qualified Offers

    Article One little-used option for resolving tax issues while in IRS Appeals is to submit a qualified offer under Sec. 7430(g). Besides making the taxpayer eligible for an award of costs, the submission of a qualified offer will often focus the IRS’s attention on the taxpayer’s case and perhaps lead to
    Published on January 28, 2011

    Impact of Anticipated COD Income on Investors Joining Existing Partnerships

    Article When appreciated property is contributed to a partnership, the precontribution gain is accounted for under Sec. 704(c), which provides that income, gain, loss, and deduction for property contributed to the partnership by a partner are shared among the partners so as to take account of the variation between the basis
    Published on January 28, 2011

    Into the Medicare Maze Decisions Facing Seniors

    Article Because health care costs can have serious detrimental effects on savings and lifestyle, understanding what Medicare covers and the difference between Medicare supplements and Medicare Advantage plans is an essential part of helping clients with retirement planning.
    Published on January 28, 2011

    Contributions of Property to an LLC

    Article The tax treatment of a contribution to a limited liability company (LLC) depends on whether the LLC is taxed as a partnership, a disregarded entity, or a corporation.
    Published on January 28, 2011

    Passive Activity Rules Not Presumed to Apply to LLCs and LLPs

    Article In the Garnett case, the Tax Court set precedent for the reporting of losses from LLPs and LLCs by limited liability partners who materially participate in the operations of the businesses in which they are investors.
    Published on January 28, 2011

    Income from Sales or Settlements of Life Insurance Contracts

    Article The IRS has provided guidance on the amount and character of income that taxpayers recognize in the surrender or sale of life insurance contracts and has provided guidance to purchasers of life insurance contracts for profit.
    Published on January 28, 2011

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