November

    The Tax Adviser November 2010 

     

     

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    IRS Releases Prop. Regs. on Series LLCs

    Article This item reviews proposed regulations the IRS released in September on the tax treatment of series limited liability companies and foreign cell companies, proposing to treat the individual series or cells as separate entities for tax purposes.
    Published on January 28, 2011

    Tax Court Again Holds That Innocent Spouse Relief Limit Is Invalid

    Article Despite being overruled by the Seventh Circuit in an earlier case, the Tax Court has again held that the regulatory two-year limitation period for filing a claim for equitable innocent spouse relief under Sec. 6015(f) is invalid. This item assesses the Tax Court's arguments in Hall, 135 T.C. No. 9
    Published on January 28, 2011

    Tax Court Again Holds That Innocent Spouse Relief Limit Is Invalid

    Article Despite being overruled by the Seventh Circuit in an earlier case, the Tax Court has again held that the regulatory two-year limitation period for filing a claim for equitable innocent spouse relief under Sec. 6015(f) is invalid. This item assesses the Tax Court's arguments in Hall, 135 T.C. No. 9
    Published on January 28, 2011

    IRS Releases Prop. Regs. on Series LLCs

    Article This item reviews proposed regulations the IRS released in September on the tax treatment of series limited liability companies and foreign cell companies, proposing to treat the individual series or cells as separate entities for tax purposes.
    Published on January 28, 2011

    Recharacterization of Income from Nonpassive to Passive Is Not a Change in Accounting Method

    Article This item examines the IRS National Office's ruling that the recharacterization of income from nonpassive to passive for purposes of the passive activity loss and credit limit rules of Sec. 469 is not a change of accounting method for purposes of Secs. 446(e) and 481(a).
    Published on January 28, 2011

    Recharacterization of Income from Nonpassive to Passive Is Not a Change in Accounting Method

    Article This item examines the IRS National Office's ruling that the recharacterization of income from nonpassive to passive for purposes of the passive activity loss and credit limit rules of Sec. 469 is not a change of accounting method for purposes of Secs. 446(e) and 481(a).
    Published on January 28, 2011

    IRS Finalizes Regs. on Tentative Carryback Adjustments

    Article The IRS released final regulations under Sec. 6411 providing guidance on the computation and allowance of tentative carryback adjustments (tentative refunds). This item outlines the contents of those regulations.
    Published on January 28, 2011

    IRS Finalizes Regs. on Tentative Carryback Adjustments

    Article The IRS released final regulations under Sec. 6411 providing guidance on the computation and allowance of tentative carryback adjustments (tentative refunds). This item outlines the contents of those regulations.
    Published on January 28, 2011

    IRS Expands Use of Electronic Payments, Discontinues Paper Coupons

    Article The IRS has issued proposed regulations that would eliminate paper coupons for deposits of employment taxes, corporate income and estimated taxes, and many other taxes.
    Published on January 28, 2011

    Draft Form for Small Business Health Insurance Credit Released

    Article The IRS has issued a draft form (Credit for Small Employer Health Insurance Premiums) for businesses to use in figuring and claiming the new small business health insurance credit, starting this year.
    Published on January 28, 2011

    Draft Form for Small Business Health Insurance Credit Released

    Article The IRS has issued a draft form (Credit for Small Employer Health Insurance Premiums) for businesses to use in figuring and claiming the new small business health insurance credit, starting this year.
    Published on January 28, 2011

    IRS Expands Use of Electronic Payments, Discontinues Paper Coupons

    Article The IRS has issued proposed regulations that would eliminate paper coupons for deposits of employment taxes, corporate income and estimated taxes, and many other taxes.
    Published on January 28, 2011

    Individual Taxation Report Recent Developments

    Article This article covers recent developments affecting the taxation of individuals, including health care reform and other legislation, regulations, cases, and IRS guidance. The items are arranged in Code section order.
    Published on January 28, 2011

    Individual Taxation Report Recent Developments

    Article This article covers recent developments affecting the taxation of individuals, including health care reform and other legislation, regulations, cases, and IRS guidance. The items are arranged in Code section order.
    Published on January 28, 2011

    Scope of Foreign Trust Provisions in the HIRE Act

    Article This article analyzes the foreign trust provisions of the HIRE Act and offers some practical guidance for practitioners to consider in their development of best practice procedures.
    Published on January 28, 2011

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