April

    The Tax Adviser April 2011 

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    Current Corporate Income Tax Developments (Part II) - 2011

    Article This article covers some of the more important developments in the areas of apportionment, unitary groups/filing methods, administration, flowthrough entities, and other significant corporate state tax issues.
    Published on January 08, 2013

    Split Widens as Courts Hold Basis Overstatement Is Not Income Omission

    Article The ongoing controversy over whether a taxpayer’s overstatement of basis triggers a six-year statute of limitation period continues as the Fourth Circuit and Fifth Circuit both held within days of each other that the extended period does not apply. These decisions are at odds with a Seventh Circuit opinion issued
    Published on June 16, 2011

    IRS Will Allow Costs of Breast Pumps as Deductible Medical Expenses

    Article The IRS has announced that it will treat expenses for breast pumps and supplies that assist in lactation as deductible medical expenses, and that the  amounts that a taxpayer is reimbursed for these expenses will not be income to the taxpayer.
    Published on June 16, 2011

    Contribution Deduction Denied for Gifts to Family Public Charity

    Article The Tax Court denied a taxpayer’s claim for a deduction for a contribution of stock to a charitable foundation that the foundation used to set up a family public charity account in which the taxpayer’s contribution was segregated for investment and future distribution at the taxpayer’s discretion.
    Published on June 16, 2011

    Court-Ordered Restitution Subject of Informal Guidance

    Article In a piece of informal guidance, the IRS Office of Chief Counsel has provided an outline of its understanding of the IRS’s new authority to assess and collect court-ordered restitution for failure to pay tax.
    Published on June 16, 2011

    Electing to Treat Musical Works as Capital Assets

    Article The IRS issued final regulations governing how to elect to treat the sale or exchange of a musical work or copyright in a musical work as a sale or exchange of a capital asset.
    Published on June 16, 2011

    Reporting Uncertain Tax Positions

    Article This item explores the differences between financial statement reporting and federal income tax return disclosure in preparing for disclosure of uncertain tax positions on the Schedule UTP,
    Published on June 16, 2011

    Increased Opportunities for Sec. 338(h)(10) Elections

    Article The Small Business Jobs Act changes the S corporation built-in gains (BIG) tax for tax years (and only for tax years) beginning in 2011. This article discusses the increased opportunities this affords buyers to elect to treat purchases of S corporation stock as asset purchases without triggering BIG tax.
    Published on June 16, 2011

    The Emergence of Factor Presence Nexus Standards

    Article Several states have replaced traditional nexus standards with factor presence nexus standards to trigger taxes based upon gross receipts and income.
    Published on June 16, 2011

    Second Offshore Voluntary Disclosure Program Started

    Article The IRS has announced that it is starting a new program designed to bring money held in foreign accounts back into the U.S. tax system and to help taxpayers with income from offshore accounts comply with federal tax law.
    Published on June 16, 2011

    IRS Refocuses Large Business Operations, Highlights International And Global High-Wealth Cases

    Article This item highlights IRS efforts to refocus the work of its former Large and Midsize Business (LMSB) Division, now known as the Large Business and International (LB&I) Division, in an effort to strengthen international compliance.
    Published on June 16, 2011

    Prop. Regs. on Sales-Based Royalties and Vendor Allowances

    Article The IRS issued much-anticipated proposed regulations on the capitalization and allocation of sales-based royalties and on adjustments to the cost of merchandise inventory for sales-based vendor allowances.
    Published on June 16, 2011

    Capital Construction Funds Sec. 7518

    Article This item reviews the Capital Construction Fund (CCF) program, which allows owners and operators of U.S. flag vessels to accumulate the large amounts of capital by deferring federal income taxes on certain deposits of money or other property placed into the fund.
    Published on June 16, 2011

    Target Allocations

    Article This item discusses what target allocations are and how they determine income allocations during a year. It also examines some special issues with target allocations.
    Published on June 16, 2011

    Form 5471 Penalties

    Article This item discusses the importance of timely filing federal income tax returns that include Form 5471, regardless of whether the return shows a balance due, because of the extensive penalties for failure to comply with the reporting requirements.
    Published on June 16, 2011

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