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    The Tax Adviser November 2011 

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    The Tax Adviser November 2011

    Publication The Magazine of Planning, Trends & Techniques
    Published on November 01, 2011

    Conflicts of Interest IRS Rules Differ from AICPA Professional Standards

    Article Circular 230 forbids federal tax practitioners from having conflicts of interest, defined as representation of one client that is directly adverse to that of another client, or representing a client in circumstances creating a significant risk that the representation of one or more clients will be materially limited by the
    Published on November 01, 2011

    Deferral of Income from Sale of Gift Cards

    Article This item summarizes the recently released Rev. Proc. 2011-18, which provides guidance on the deferral of income from the sale of gift cards.
    Published on November 01, 2011

    Current Developments in Employee Benefits and Pensions (Part I)

    Article This article covers significant developments in late 2010 and 2011 in employee benefits, including employment taxes, executive compensation, health and welfare benefits, and qualified plans. Part I focuses on guidance released and changes to the rules for employment taxes and executive compensation.
    Published on November 01, 2011

    Software and California Sales and Use Tax

    Article This item addresses the sales and use tax implications of canned software (prewritten programs) under two recent California cases in light of that state's current statutory scheme.
    Published on November 01, 2011

    Offers in Compromise and the Consideration of Dissipated Assets

    Article This item reviews the qualification requirements for an offer in compromise, a form of administrative relief offered to financially distressed taxpayers with outstanding tax liabilities who are unable to satisfy their obligations to the government.
    Published on November 01, 2011

    IRS Revamps Lien Procedures to Help Struggling Taxpayers

    Article The IRS has revised its tax lien filing practices and provisions.
    Published on November 01, 2011

    California Changes Combined Reporting for Assignment of Combined Group Sales

    Article For tax years beginning on or after January 1, 2011, California requires that receipts from the sale of tangible personal property of all members of a combined reporting group be assigned (i.e., sourced) to California, regardless of whether a specific member has nexus in the state.
    Published on November 01, 2011

    Californias Click-Through Nexus Law

    Article In 2011, California enacted a “click-through nexus” law requiring out-of-state online retailers to collect sales tax on all taxable sales of tangible personal property made through internet-based referrals, effective Sept. 2012.
    Published on November 01, 2011

    Employers Immune from Suit for Complying with IRS Levy

    Article This item addresses an employer’s rights and responsibilities when required to comply with an IRS wage levy against an employee.
    Published on November 01, 2011

    International Students and the American Opportunity Tax Credit

    Article The tax compliance of international students is now a more critical issue because of the partially refundable nature of the American opportunity tax credit.
    Published on November 01, 2011

    The Codified Economic Substance Doctrine and Related Penalties

    Article The IRS issued a directive providing details on a multistep process that examiners must follow before the ultimate application of the economic substance doctrine in an examination. It also provides guidance on related penalties that might be imposed upon the application of the doctrine.
    Published on November 01, 2011

    Updated Guidance on the Determination of Basis of Stock in Transferred Basis Transactions

    Article Rev. Proc. 2011-35 provides four safe-harbor methodologies that a corporation may use to establish its basis in the stock of another corporation in a type B reorganization or certain other transferred basis transactions.
    Published on November 01, 2011

    Keeping Alimony from Being Reclassified as Nondeductible Payments

    Article This column discusses the tax implications of alimony or spousal support, with a focus on the specific criteria that payments must meet to qualify as alimony.
    Published on November 01, 2011

    Current Developments in S Corporations (Part II)

    Article This article provides an annual update of recent IRS rulings, guidance, and other developments concerning S corporations. It discusses S corporation eligibility, elections, termination issues, second class of stock, and trusts owning S corporation stock.
    Published on November 01, 2011

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