The Tax Adviser September 2009 



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    Maneuvering Through the Proposed Rules for Post-Transaction Accounting Methods

    Article Proposed regulations address the process for determining and changing methods of accounting following certain corporate reorganizations and liquidations.
    Published on January 28, 2011

    Method Changes Within the Nonaccrual Experience Method

    Article A nonaccrual experience method of accounting, as described in Sec. 448(d) (5), allows certain service providers to except from accrual the portion of revenue they have determined will not be collected, based on their own experience and through the use of formulas allowed under this section and the regulations.
    Published on January 28, 2011

    AMT Consequences of an Ownership Change

    Article While most tax planning routinely contemplates the impact of the Sec. 382 limitation on the use of a corporation’s net unrealized built-in losses (NUBILs) following an ownership change, the corresponding impact of Sec. 56(g)(4)(G) for adjusted current earnings (ACE) is often overlooked and may have a significantly different effect than
    Published on January 28, 2011

    Drop Shipments and Flash Title Establishing Sales Tax Nexus in Complex Commercial Transactions

    Article This column discusses substantial and attributional nexus and examines how nexus is asserted for sales and use tax purposes in drop shipment and flash title transactions.
    Published on January 28, 2011

    Deferring Shareholder Gain by Distributing Installment Notes

    Article When a C corporation sells some or all of its assets during the process of liquidation and takes back one or more installment notes as payment, it must recognize, in the year of liquidation, all unrecognized gains on installment receivables distributed to the shareholders (Secs. 336 and 453B(a)).
    Published on January 28, 2011

    Debt Restructurings in Todays Private Equity Environment

    Article Deals that are taking place today bring with them many technical tax considerations that were seen much less frequently during robust economic times.
    Published on January 28, 2011

    Creative Ways of Achieving Grantor Trust Status

    Article Trusts that may not appear to qualify as S corporation shareholders could actually be grantor trusts eligible to own S corporation stock.
    Published on January 28, 2011

    ETAAC Makes Recommendations to Congress, Including Mandatory E-Filing

    Article The Electronic Tax Administration Advisory Committee made 10 recommendations to help the IRS achieve its goal that 80% of all tax and information returns be e-filed.
    Published on January 28, 2011

    Client Data Security for the Tax Practitioner

    Article This column takes a brief look at some practices CPAs should consider when handling data security.
    Published on January 28, 2011

    2009 Tax Software Survey

    Article The Tax Adviser and the Journal of Accountancy conducted a survey of their readers to determine what aspects of their tax preparation software they like and what they dislike.
    Published on January 28, 2011

    Partnership Structural Changes Deductibility of Expenses

    Article This item examines several partnership restructuring transactions and discusses the circumstances in which a restructuring expense can be deducted and amortized under Sec. 709 or must be capitalized under Regs. Sec. 1.263(a)-5(a).
    Published on January 28, 2011

    Chief Counsel Outlines Litigation Tactics for Innocent Spouse Cases

    Article The IRS Chief Counsel’s office has released a memorandum outlining IRS litigation tactics in innocent spouse cases (CC-2009-021).
    Published on January 28, 2011

    Sec. 83 in the Context of Contract Manufacturing

    Article Sec. 83 may be applied to successfully defer and possibly reduce taxable compensation to independent contractors, including contract manufacturers.
    Published on January 28, 2011

    Interests in LLCs and LLPs Not Presumed to Be Passive Activities

    Article The Tax Court held that the taxpayers’ interests in their LLPs and LLCs were not presumptively passive because they did not hold their interests in the entities as limited partners in a limited partnership.
    Published on January 28, 2011

    Preparing Canadian Structures for 2010

    Article Effective January 1, 2010, Canada will look through tax-transparent U.S. LLCs and determine treaty eligibility at the member level.
    Published on January 28, 2011

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