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

    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

    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 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

    IRS Whistleblower Program Evaluated

    Article Editor: John L. Miller, CPA On September 30, 2009, the IRS Whistleblower Office released its 2009 annual report to Congress outlining claims made under Sec. 7623. In a related action, on October 8, 2009, the Treasury Inspector General for Tax Administratio
    Published on January 28, 2011

    New Directives from the LMSB

    Article The IRS Large and Mid-Size Business (LMSB) Division has issued several new directives related to issues targeted under its issue-tiering strategy.
    Published on January 28, 2011

    LMSB Identifies New Repairs Issue

    Article In an IRS Large and Mid-Size Business (LMSB) Division memorandum (LMSB-4-0509-019), the IRS notified LMSB executives of an emerging issue relating to the recharacterization of costs associated with tangible assets previously capitalized under Sec. 263(a) as currently deductible repairs under Sec. 162.
    Published on January 28, 2011

    IRS Finalizes Regs. on Reporting for Discharges of Indebtedness

    Article The IRS has issued final regulations (T.D. 9461) on information returns for cancellation of indebtedness by certain entities under Sec. 6050P.
    Published on January 28, 2011

    Commissioner Announces High-Wealth Taxpayers Group

    Article IRS Commissioner Douglas Shulman addressed the AICPA’s National Tax Conference in Washington, DC, on October 26. During his speech, Shulman announced the formation of a global high-wealth industry group within the IRS’s Large and Mid-Size Business (LM
    Published on January 28, 2011

    Definition of Omission from Gross Income for Partnership Items and the Six-Year Period for Assessing Tax

    Article The IRS has issued temporary and proposed regulations defining an omission from gross income for purposes of the six-year minimum period for assessment of tax attributable to partnership items and the six-year period for assessing tax.
    Published on January 28, 2011

    Obtaining a Power of Attorney Through IRS E-Services

    Article E-services is a suite of internet-based products that allows tax professionals to conduct client business with the IRS 24 hours a day, 7 days a week.
    Published on January 28, 2011

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