Taxation of LLC Members as General Partners

Article:  In recent decisions, courts have held that interests in an LLC that elects to be treated as a partnership for federal income tax purposes should not be treated as limited partnership interests per se.
Published on January 28, 2011

Closing Date Deadline for Homebuyer Credit Extended to September 30

Article:  The Homebuyer Assistance and Improvement Act extends the closing date deadline to qualify for the first-time homebuyer credit from June 30, 2010, to September 30, 2010.
Published on January 28, 2011

Act Provides Temporary Funding Relief for Pension Plans

Article:  The Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act allows single-employer plans to elect to amortize over a longer period pension shortfalls caused by losses in asset value they experienced in 2008.
Published on January 28, 2011

IRS Proposes PTIN Fees

Article:  The IRS proposed to begin charging all authorized tax preparers a $50 user fee to obtain or renew annually a preparer tax identification number (PTIN).
Published on January 28, 2011

IRS Announces Phase-in of Mandatory E-Filing

Article:  The Worker, Homeownership, and Business Assistance Act mandates e-filing by almost all return preparers; it requires any return preparer who files more than 10 individual income tax returns per year to e-file those returns, starting in 2011.
Published on January 28, 2011

IRS Launches Gulf Oil Spill Hotline

Article:  The IRS announced that it has set up a special toll-free telephone line for taxpayers affected by the oil spill in the Gulf of Mexico.
Published on January 28, 2011

CPA Conflicts of Interest

Article:  Avoiding conflicts of interest requires CPAs to aggressively identify potential conflicts and take appropriate remedial action.
Published on January 28, 2011

Significant Recent Developments in Estate Planning (Part I)

Article:  This article examines developments in estate, gift, and generation-skipping tax planning and compliance between June 2009 and May 2010.
Published on January 28, 2011

Taxpayer Denied Exclusion for Gain on the Sale of a Principal Residence

Article:  The Tax Court held that taxpayers who demolished a home they had lived in for more than two years, built a new home on the same lot, and then sold the new home without ever living in it were not entitled to exclude the gain from the sale from income
Published on January 28, 2011

Tax Lien Attached to Property Transferred in Divorce

Article:  The IRS Office of Chief Counsel advised a member of the National Taxpayer Advocate Office that a tax lien attached to property that a husband transferred to his wife in a divorce settlement where the quitclaim deed conveying the property was not registered prior to the filing of a Notice
Published on January 28, 2011

Avoiding the Below-Market Rules on Corporation/Shareholder Loans

Article:  The below-market loan rules apply to all advances, notes, and receivables between a shareholder and a corporation, regardless of the shareholder’s level of ownership.
Published on January 28, 2011

Extended NOL Carrybacks and the AMT

Article:  The addition and expansion of the Sec. 172(b)(1)(H) election has created numerous tax planning opportunities for corporations that have sustained NOLs; the ability to change the character of election-year ATNOLs creates an additional benefit of making this election.
Published on November 23, 2010

Income Apportionment and Allocation after Mead

Article:  In MeadWestvaco Corp. v. Illinois Dep’t of Revenue, the Supreme Court held that the operational function test was not intended to modify the unitary business principle by adding a new ground for apportionment.
Published on October 20, 2010

Tax Treatment of Expenses Incurred by Individuals Temporarily Out of Work

Article:  This article examines the tax treatment of expenses incurred by individuals who are temporarily out of work.
Published on September 21, 2010

Leaving Retirement Benefits to Trusts Pitfalls for the Unwary

Article:  There are a variety of legitimate reasons that a participant may believe it prudent to leave retirement plan benefits in trust for the benefit of the spouse. It is important that advisers are aware of the potential pitfalls associated with this option and understand the participant’s ultimate objective for the
Published on September 01, 2010