January

    The Tax Adviser January 2010 

     

     

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    Restaurant Management Company May Not Defer Recognition of Income from Gift Card Sales

    Article The IRS has determined in a legal advice memorandum (20093801F) that a restaurant management company may not defer income recognition from the proceeds of gift card sales under Regs. Sec. 1.451-5 or Rev. Proc. 2004-34.
    Published on January 28, 2011

    Restaurant Management Company May Not Defer Recognition of Income from Gift Card Sales

    Article The IRS has determined in a legal advice memorandum (20093801F) that a restaurant management company may not defer income recognition from the proceeds of gift card sales under Regs. Sec. 1.451-5 or Rev. Proc. 2004-34.
    Published on January 28, 2011

    New Accounting Methods Subject to Automatic Change Procedures

    Article The IRS has issued new guidance on automatic accounting method changes.
    Published on January 28, 2011

    New Accounting Methods Subject to Automatic Change Procedures

    Article The IRS has issued new guidance on automatic accounting method changes.
    Published on January 28, 2011

    Safe-Harbor Lookthrough Treatment for RIC Investments in PPIPs

    Article The IRS has outlined a safe harbor for regulated investment companies (RICs) for purposes of the Sec. 851(b)(3) asset diversification tests that treats a RIC as if it directly invested in the assets held by a publicprivate investment partnership (PPIP) in which it invests.
    Published on January 28, 2011

    C Corporations as S Corporation Subsidiaries

    Article An S corporation can elect to treat a 100% owned subsidiary as a qualified subchapter S subsidiary (QSub), which causes the subsidiary to be disregarded for most federal tax purposes. The subsidiary must be a corporation that would be eligible to be an S corporation if the shareholders of its
    Published on January 28, 2011

    Final Regs. Issued on S Corp. DOI Income Exclusion and Tax Attributes

    Article The IRS issued final regulations governing how an S corporation reduces its tax attributes under Sec. 108(b) when the S corporation has discharge of indebtedness income that is excluded from gross income under Sec. 108(a).
    Published on January 28, 2011

    C Corporations as S Corporation Subsidiaries

    Article An S corporation can elect to treat a 100% owned subsidiary as a qualified subchapter S subsidiary (QSub), which causes the subsidiary to be disregarded for most federal tax purposes. The subsidiary must be a corporation that would be eligible to be an S corporation if the shareholders of its
    Published on January 28, 2011

    Final Regs. Issued on S Corp. DOI Income Exclusion and Tax Attributes

    Article The IRS issued final regulations governing how an S corporation reduces its tax attributes under Sec. 108(b) when the S corporation has discharge of indebtedness income that is excluded from gross income under Sec. 108(a).
    Published on January 28, 2011

    Safe-Harbor Lookthrough Treatment for RIC Investments in PPIPs

    Article The IRS has outlined a safe harbor for regulated investment companies (RICs) for purposes of the Sec. 851(b)(3) asset diversification tests that treats a RIC as if it directly invested in the assets held by a publicprivate investment partnership (PPIP) in which it invests.
    Published on January 28, 2011

    IRS Expands List of Permitted Loan Modifications to Include Commercial Mortgages Held by REMICs

    Article The IRS has issued final regulations (T.D. 9463) expanding the list of permitted loan modifications to include certain modifications of commercial mortgages held by real estate mortgage investment conduits (REMICs).
    Published on January 28, 2011

    IRS Workforce Initiative

    Article To prepare for the future, the IRS has established a Workforce of Tomorrow task force, with six areas of focus.
    Published on January 28, 2011

    IRS Workforce Initiative

    Article To prepare for the future, the IRS has established a Workforce of Tomorrow task force, with six areas of focus.
    Published on January 28, 2011

    IRS Expands List of Permitted Loan Modifications to Include Commercial Mortgages Held by REMICs

    Article The IRS has issued final regulations (T.D. 9463) expanding the list of permitted loan modifications to include certain modifications of commercial mortgages held by real estate mortgage investment conduits (REMICs).
    Published on January 28, 2011

    Request for Audit Reconsideration

    Article Sec. 6404(a) allows the IRS to abate any assessment of tax and applicable interest and/or penalties if the assessment is excessive, erroneously or illegally made, or made after the statute of limitation has expired. If an erroneous assessment has been made and a taxpayer has not paid it, under certain
    Published on January 28, 2011

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