The Tax Adviser July 2011 


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    The Tax Adviser July 2011

    Published on August 01, 2011

    Equity-Based and Nonqualified Deferred Compensation Plans

    Article This article provides an overview of the federal income taxation rules governing equity-based compensation plans as well as nonqualified deferred compensation plans.
    Published on July 01, 2011

    IRS Matching Program for Forms 8023 and 8883 May Result in Invalid Sec. 338 Election

    Article The IRS recently launched a program to match the filing of Form 8023, Elections Under Section 338 for Corporations Making Qualified Stock Purchases, by a foreign purchasing corporation acquiring a foreign target, with Form 8883, Asset Allocation Statement Under Section 338, to report the effect of the Sec. 338 election.
    Published on July 01, 2011

    Special Limitation Periods for Carryback Assessments

    Article By exercising its setoff authority, the IRS has been able to achieve the same limitation period in Form 1120X carryback situations as in tentative refund cases with Form 1139.
    Published on July 01, 2011

    Partnership Determination of Eligible Basis for Energy Grants

    Article This item discusses whether a partnership should take a partner’s Sec. 743(b) adjustment into account in determining eligible basis of qualified energy property that the partnership has not yet placed in service.
    Published on July 01, 2011

    Employment Tax Consequences of a Corporate Change of Control Event

    Article This item examines the employment tax consequences related to a corporate change of control event. Those consequences generally depend on the type of event, namely whether there is an asset purchase, a merger, or a stock acquisition.
    Published on July 01, 2011

    The Impact of Unified Loss Rules on Earnings and Profits

    Article This item explores whether an adjustment is made for E&P purposes when a member of a consolidated group is required under the unified loss rules to reduce its basis in the stock of another member for regular tax purposes upon the first member's disposition of the second member's stock at a loss
    Published on July 01, 2011

    LLC Member Debt Recourse or Nonrecourse

    Article How should deductions be allocated that are funded by a general obligation of an LLC if the obligation is guaranteed by or borrowed from a member and is recourse debt under Sec. 1001?
    Published on July 01, 2011

    Application of CFC Lookthrough Rule to Payments Made by a Partnership to Its CFC Partner

    Article This item examines the controlled foreign corporation (CFC) lookthrough rule.
    Published on July 01, 2011

    Ordinary Worthless Stock Deductions Characterizing Subsidiary Receipts

    Article An ordinary loss deduction for worthless stock of an affiliated operating subsidiary generally is permitted as long as more than 90% of the subsidiary’s gross receipts are from active operating income. This item discusses the difficulty of determining whether a subsidiary’s gross receipts qualify as active operating income for this purpose
    Published on July 01, 2011

    One Reorganization, Two Tax Years, One Practical Solution

    Article This item considers what is the proper time to report the transaction if a reorganization spans different tax years.
    Published on July 01, 2011

    IRS Applies Reverse Acquisition Regulations A Substance-over-Form Approach

    Article Determining whether a transaction is characterized as a reverse acquisition under the consolidated return regulations can be challenging. This item focuses on tax implications of reverse acquisitions and reviews recent private letter rulings in which the IRS applied substance-over-form principles.
    Published on July 01, 2011

    Taxing Intellectual Property Transfers

    Article Outbound transfers of intellectual property can raise difficult tax issues for U.S. persons.
    Published on July 01, 2011

    New Form 990 Whats Confusing Filers

    Article The redesigned Form 990 has been the subject of much discussion since the IRS released it in 2007, and several areas of confusion have been identified. This item highlights problems frequently encountered by practitioners, including many compensation issues.
    Published on July 01, 2011

    FIRPTA and the Return of Capital Distributions

    Article FIRPTA is quite complex and filled with traps for the unwary, especially in the area of return of capital distributions.
    Published on July 01, 2011

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