The Tax Adviser August 2011 




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    When Is a U.S. LLC a Partnership for U.S. and U.K. Tax Purposes

    Article U.S. LLCs have become the preferred business entity in many situations because their members get both legal liability protection while being taxed in the United States as a partnership. This item examines how profits and losses of a U.S. LLC will be taxed on a U.K. resident’s U.K. tax return.
    Published on October 23, 2013

    Claiming Bonus Depreciation on Self-Constructed Long Production Period Assets

    Article This item discusses the process of claiming bonus depreciation on self-constructed long production period assets, with a  focus on how the taxpayer can determine how the binding contract rules and placed-in-service rules apply to particular projects.
    Published on July 13, 2012

    2010 Best Article Award

    Article Announcement of the winner of the Tax Adviser's 2010 Best Article Award.
    Published on July 12, 2012

    S Corporation Shareholder Compensation How Much Is Enough

    Article This article looks at recent court decisions regarding S corporation shareholder reasonable compensation that provide helpful guidance on how an adviser can determine what is reasonable compensation.
    Published on April 20, 2012

    Codification of Economic Substance Affects All Tax Practitioners

    Article This column discusses uncertainty surrounding the codification of the economic substance doctrine and explores selected areas of impact on CPAs’ professional obligations and practice.
    Published on January 13, 2012

    No Reasonable Cause for $3.4 Million Omission from Income

    Article The Tax Court held that a taxpayer did not have reasonable cause for omitting from income $3.4 million from the termination of a swap transaction that was reported to him on a Form 1099.
    Published on January 13, 2012

    Charitable Deduction Allowed for Expenses of Cat Rescue Organization Volunteer

    Article The Tax Court allowed a taxpayer to take a charitable deduction for expenses she incurred while taking care of cats for a charitable organization dedicated to cat neutering and rescue because her expenses were incident to services provided to a charitable organization.
    Published on January 13, 2012

    IRS Removes Form 5472 Duplicate Filing Requirement

    Article The IRS has issued temporary and proposed regulations to remove the duplicate filing requirement for Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.
    Published on January 13, 2012

    Diversifying Concentrated Positions in the Most Tax-Efficient Manner

    Article This item explores techniques that may be used to the advantage of investors wishing to diversify concentrated securities positions in a tax-efficient manner.
    Published on January 13, 2012

    Planning for the Unearned Income Medicare Contribution Tax

    Article The unearned income Medicare contribution tax is scheduled to come to life at the end of next year, and it may have a significant impact on some taxpayers.
    Published on January 13, 2012

    Separately Identifiable Intangible Assets Tax Opportunities and Traps

    Article Treating self-created customer-based intangibles as assets separate from goodwill can result in more favorable tax treatment for these intangibles. This article examines the rules regarding the separate treatment of self-created customer-based intangibles and the situations in which separate treatment may be beneficial.
    Published on January 13, 2012

    Two-Year Innocent Spouse Limitation Period Upheld Again

    Article The Fourth Circuit overturned a Tax Court decision and upheld a Treasury regulation that sets a two-year statute of limitation on claims for innocent spouse relief, marking the third time the Tax Court has been overruled on this issue by a higher court.
    Published on January 13, 2012

    Final Circular 230 Regs. Implement Preparer Registration Rules

    Article The IRS has issued final regulations implementing components of its initiative to register and regulate all paid tax return preparers.
    Published on January 13, 2012

    IRS and FinCEN Extend FBAR Deadlines for Certain Filers

    Article The IRS has further extended the deadline for certain persons to file an FBAR form for 2009 and earlier years. U.S. persons with a financial interest in, or signature authority over, any financial accounts in a foreign country must file an FBAR if the aggregate value of these accounts exceeds
    Published on January 13, 2012

    Alternative Simplified R&D Credit Rules Finalized

    Article The IRS has issued final regulations governing the election and calculation of the alternative simplified research and development credit. The regulations extend the election procedures for the alternative incremental research credit to the alternative simplified credit.
    Published on January 13, 2012

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