May

    The Tax Adviser May 2011 

     

     

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    Schedule UTP IRS Mandates Disclosure of Uncertain Tax Positions

    Article This article explores the requirements of Schedule UTP, discusses modifications to the IRS’s policy of restraint pertaining to tax reconciliation workpapers, and suggests how to avoid the inadvertent waiver of the work-product privilege for documents relating to uncertain tax positions.
    Published on April 02, 2014

    Schedule UTP IRS Mandates Disclosure of Uncertain Tax Positions

    Article This article explores the requirements of Schedule UTP, discusses modifications to the IRS’s policy of restraint pertaining to tax reconciliation workpapers, and suggests how to avoid the inadvertent waiver of the work-product privilege for documents relating to uncertain tax positions.
    Published on April 02, 2014

    Violation of Public Policy and the Denial of Deductions

    Article Recent events have drawn attention to the disallowance of deductions where allowing the deductions would violate public policy. This article discusses the disallowance of deductions under Sec. 162 and Sec. 165 for public policy reasons.
    Published on April 20, 2012

    Violation of Public Policy and the Denial of Deductions

    Article Recent events have drawn attention to the disallowance of deductions where allowing the deductions would violate public policy. This article discusses the disallowance of deductions under Sec. 162 and Sec. 165 for public policy reasons.
    Published on April 20, 2012

    Day-Trading Losses Are Dissipation of Assets

    Article The Tax Court held that a taxpayer’s losses from a period of day-trading activity constituted a dissipation of assets that the IRS could take into account in determining whether to accept the taxpayer’s offer in compromise.
    Published on July 20, 2011

    Day-Trading Losses Are Dissipation of Assets

    Article The Tax Court held that a taxpayer’s losses from a period of day-trading activity constituted a dissipation of assets that the IRS could take into account in determining whether to accept the taxpayer’s offer in compromise.
    Published on July 20, 2011

    Cooperative Owner Cannot Deduct Cooperatives Casualty Loss

    Article A shareholder in a cooperative housing corporation was not allowed to deduct as a casualty loss an assessment levied against her by the cooperative to pay for damages caused by the collapse of a retaining wall on its property.
    Published on July 20, 2011

    Cooperative Owner Cannot Deduct Cooperatives Casualty Loss

    Article A shareholder in a cooperative housing corporation was not allowed to deduct as a casualty loss an assessment levied against her by the cooperative to pay for damages caused by the collapse of a retaining wall on its property.
    Published on July 20, 2011

    Extended Period for Receiving Authorization to Disclose Return Information Proposed

    Article The IRS issued a proposed regulation that would officially extend from 60 to 120 days the permitted period for submission of taxpayer authorizations allowing disclosure of returns and return information to third-party designees because some financial institutions have had difficulty obtaining and submitting written authorizations within the current 60-day limit.
    Published on July 20, 2011

    Extended Period for Receiving Authorization to Disclose Return Information Proposed

    Article The IRS issued a proposed regulation that would officially extend from 60 to 120 days the permitted period for submission of taxpayer authorizations allowing disclosure of returns and return information to third-party designees because some financial institutions have had difficulty obtaining and submitting written authorizations within the current 60-day limit.
    Published on July 20, 2011

    Tax Practice Responsibilities

    Article This new quarterly column addresses the tax practice responsibilities part of CPA tax professionals’ practice and provides information that will enable practitioners to become better informed about and meet their legal, regulatory, and ethical responsibilities as professionals.
    Published on July 20, 2011

    Tax Practice Responsibilities

    Article This new quarterly column addresses the tax practice responsibilities part of CPA tax professionals’ practice and provides information that will enable practitioners to become better informed about and meet their legal, regulatory, and ethical responsibilities as professionals.
    Published on July 20, 2011

    IRS Announces Tax-Exempt Bond Voluntary Closing Agreement Program

    Article The IRS has announced a program to provide relief from debt extinguishment for certain issuers that purchase and hold their own tax-exempt bonds.
    Published on July 20, 2011

    IRS Announces Tax-Exempt Bond Voluntary Closing Agreement Program

    Article The IRS has announced a program to provide relief from debt extinguishment for certain issuers that purchase and hold their own tax-exempt bonds.
    Published on July 20, 2011

    IRS Announces Changes to Lien Process

    Article The IRS has announced a set of new policies designed to help taxpayers pay their back taxes and avoid liens. It also announced that it is making it easier for taxpayers to enter into an installment agreement and is expanding its streamlined offer in compromise program.
    Published on July 20, 2011

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