October

    The Tax Adviser October 2011 

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    Unrelated Business Income from Alternative Investments State Considerations

    Article This item outlines possible tax compliance issues that nonprofit organizations should consider, particularly the focus from state taxing jurisdictions on unrelated business income generated by alternative investments.
    Published on April 17, 2012

    Some Implications of 100% Bonus Depreciation

    Article This item discusses optimization of the 100% bonus depreciation deduction, highlighting some of its implications and peculiarities.
    Published on April 17, 2012

    At-Risk Limitation on Deducting an LLC Members Losses

    Article This column reviews the at-risk regulations, which are applied at the individual member level to losses passed through from an LLC, with a focus on determining what constitutes a separate activity, how to handle real estate activities, and aggregating at-risk activities.
    Published on April 17, 2012

    Are Hedge Funds and Private Equity Funds Foreign Financial Accounts

    Article This item discusses whether investments in or management of hedge funds and private equity funds should be included within the scope of the FBAR filing requirements.
    Published on April 17, 2012

    Passive Foreign Investment Companies

    Article This item assesses various planning alternatives that may help U.S. taxpayers avoid the negative aspects of the PFIC regime, including qualifying electing funds, mark-to-market elections, and various planning strategy options.
    Published on April 17, 2012

    Shareholder Loan Documentation

    Article This item explores the importance of paying attention to details and following document terms for shareholder loans.
    Published on April 17, 2012

    Forgivable Loans in Employment Agreements

    Article The item examines the use of forgivable loans issued at the inception of employment, where the employee receives an upfront payment of cash and the related income arising from the forgiveness of such debt is recognized over the life of the obligation provided in the agreement.
    Published on April 17, 2012

    Exchange of Shares in ISO Exercise

    Article Under Regs. Sec. 1.6045-1(d)(2), which requires that broker statements disclose securities’ adjusted basis beginning January 1, 2011, basis tracking of ISOs is more relevant than ever.
    Published on April 17, 2012

    Sec. 1033 Can Allow for Flexible Tax-Free Reinvestments

    Article This item discusses tax strategies taxpayers can use in dealing with the involuntary conversion of real property. Under Sec. 1033, a taxpayer can elect to defer the gain on the conversion of such property if the property is replaced by, or the proceeds are reinvested in, similar or related use
    Published on April 17, 2012

    Sec. 1031 Related-Party Exchanges and Basis Shifting

    Article The Code provides a number of related-party exceptions designed to circumvent certain abuses, the most prevalent of which is basis shifting. This item discusses ways that practitioners can avoid basis-shifting problems.
    Published on April 17, 2012

    Relief for Late Election to Treat All Real Estate Rental Interests as One Activity

    Article This item reviews recent IRS guidance on how certain taxpayers can make a late election to treat all interests in rental real estate as a single rental real estate activity.
    Published on April 17, 2012

    New Developments in Sourcing Services for Telecommunication Companies

    Article Effective planning and recordkeeping in the apportionment area call for an in-depth understanding of a taxpayer’s business model, including technology-based processes and the related cost accounting systems used, in order to source revenues to the appropriate jurisdiction.
    Published on April 17, 2012

    QSSTs and ESBTs No Longer Mutually Exclusive

    Article Under Letter Ruling 201122003, if a current ESBT allows for separate and independent trust shares under the trust document, a trust may be treated as both an ESBT and a QSST. This ruling opens the door for additional planning for gifts of S corporation stock to younger generations.
    Published on April 17, 2012

    The Targeted Allocations Approach A Basic Primer

    Article This item discusses a growing trend in the allocation provisions of partnership agreements in which limited partnerships have been adopting a targeted allocation approach through which “tax follows cash.”
    Published on April 17, 2012

    Opportunities with Nonbusiness Income and State Apportionment

    Article By performing a careful analysis of business and nonbusiness income, advisers may be able to remove the portion related to nonbusiness income from taxation. However, the throwback rule, if applicable, may negate this opportunity.
    Published on April 17, 2012

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