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

    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

    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

    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 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

    Form 990 Filing Deadline for Tax-Exempt Hospitals Delayed

    Article The IRS has announced that it is granting certain tax-exempt hospitals an automatic three-month extension of time to file their 2010 Forms 990. The automatic extension applies to Forms 990 with a due date before August 15, 2011; the IRS is also directing affected hospitals not to file before July
    Published on July 20, 2011

    Transitional Relief for Some Stock Basis Reporting Requirements

    Article The IRS has provided transitional relief from the information reporting requirements that apply to issuers of stock regarding organizational actions that affect stock basis.
    Published on July 20, 2011

    IRS Releases 2011 Automobile Depreciation Limits

    Article The IRS has issued the 2011 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles. This year, the IRS has provided the limitation amounts for vehicles placed in service in 2011 for which bonus depreciation applies and for those to which it does not apply.
    Published on July 20, 2011

    Final Regs. Issued on Disclosing Return Information to Whistleblowers

    Article The IRS released final regulations regarding the disclosure of return information by the Treasury Department in connection with written contracts among the IRS, whistleblowers, and, if applicable, their legal representatives.
    Published on July 20, 2011

    Favorable Guidance Issued on Deferral of Gift Card Sales and Gift Cards Issued for Returned Goods

    Article The IRS issued two taxpayer-favorable revenue procedures addressing the treatment of payments received for gift cards.
    Published on July 20, 2011

    S Corporation Reasonable Compensation

    Article A recent district court decision highlights the employment tax risks to S corporations that are found to have paid unreasonably low compensation to shareholder-employees while making distributions to the same individuals.
    Published on July 20, 2011

    Case Addresses the Sec. 752 Anti-Abuse Regs.

    Article The recent decision of the Tax Court in Canal Corp. may provide some insight into when a partner’s potential obligation to pay partnership debts will be disregarded in determining liability allocations.
    Published on July 20, 2011

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