The Tax Adviser May 2010 




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    Sec. 199 Domestic Production Activities Deduction

    Article Since 2004, Sec. 199 has allowed as a deduction a percentage of qualifying production expenses, with “production” defined broadly and requiring only that it take place “in significant part” within the United States.
    Published on May 03, 2011

    The Accuracy-Related Penalty (Part II)

    Article This article discusses the Sec. 6664 reasonable cause and good-faith defense to the Sec. 6662 penalty.
    Published on April 27, 2011

    Transaction Cost Update

    Article This item discusses recent taxpayer-favorable guidance provided by the IRS and the Tax Court on the tax treatment of transaction costs.
    Published on January 28, 2011

    Tax Consequences of De Facto Liquidations

    Article Under specific facts, a corporation may be deemed to have liquidated for income tax purposes without an actual legal liquidation. This is referred to as a de facto liquidation. This principle can trigger income tax consequences for both the company and its shareholders.
    Published on January 28, 2011

    Carryover Basis for Property Acquired from a Decedent Dying During 2010

    Article For property acquired from a decedent dying during 2010, a modified carryover basis regime will apply (Sec. 1022).
    Published on January 28, 2011

    AICPA Positions on Recent IRS Proposals

    Article The AICPA's Tax Division has prepared summaries of AICPA efforts regarding recent IRS proposals on return preparer registration and uncertain tax positions.
    Published on January 28, 2011

    IRS Will Process Medical Residents FICA Refund Claims for Periods Before April 1, 2005

    Article The IRS has announced that it will accept that medical residents are exempt from FICA taxes under the student exception in Sec. 3121(b)(10) for periods ending before April 1, 2005.
    Published on January 28, 2011

    Sec. 7874 New Regs. Tighten the Anti-Inversion Rules

    Article Final and temporary regulations under Sec. 7874 that clarify and expand a number of rules concerning inversions of domestic corporations.
    Published on January 28, 2011

    Congress Enacts Hiring Incentives Act with Tax Provisions

    Article The Hiring Incentives to Restore Employment Act contains several tax items, the biggest of which is a payroll tax credit for employers who hire workers who have been unemployed for at least 60 days and who are not replacement hires.
    Published on January 28, 2011

    IRS Provides Guidance on Deemed Dispositions by Canadian Emigrants

    Article The IRS has issued guidance for individuals who emigrate from Canada and wish to make an election under the U.S.-Canada income tax treaty regarding Canadian departure tax (Rev. Proc. 2010-19).
    Published on January 28, 2011

    Deducting Deficiency Interest Expense in the Proper Tax Year

    Article Deficiency interest is often overlooked after the audit cycle closes. Taxpayers can effectively plan the timing of deducting deficiency interest simply by being aware of when proposed audit adjustments are agreed upon.
    Published on January 28, 2011

    Deduction for Bonuses Deferred Due to Employment Contingency

    Article The IRS Office of Chief Counsel has concluded that a liability arising from bonus compensation is deductible in the year the bonus is paid if payment of the bonus is contingent on the taxpayer’s employees being employed on the payout date.
    Published on January 28, 2011

    The Road to Transparency

    Article The IRS has more examination tools than ever to evaluate tax compliance, and, if Announcement 2010-9 is any indication, this trend is not likely to reverse.
    Published on January 28, 2011

    IRS Proposes New Tax Return Preparer Standards

    Article The IRS released a list of recommendations calling for the registration, testing, and continuing education of currently unregulated tax return preparers.
    Published on January 28, 2011

    Reporting Uncertain Tax Positions to the IRS

    Article On January 26, 2010, the IRS issued Announcement 2010-9, indicating that it intends to require certain corporate taxpayers to disclose information about their uncertain tax positions on their tax returns.
    Published on January 28, 2011

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