The S Corporation Built-In Gains Tax Commonly Encountered Issues
Article:
This article examines five issues corporations commonly encounter in complying with the built-in gains tax.
Published on April 19, 2013
Impact of Millennials on CPA Firms
Article:
As members of the Millennial generation continue to enter the workforce, CPA firms will increasingly need to focus on how to successfully attract, motivate, develop, and retain these individuals.
Published on March 18, 2013
ODC Tax Liability and Audit Information Cannot Be Disclosed
Article:
The Federal Circuit held that audit tests and related information of third-party taxpayers pertaining to the assessment of the ozone-depleting chemicals excise tax was return information not subject to disclosure under Sec. 6103(a).
Published on March 18, 2013
Banks Are Lenders to Partnership, Not Partners
Article:
The Second Circuit held that two banks were lenders to a partnership, not partners in the partnership under Sec. 704(e)(1).
Published on March 18, 2013
Sec. 402(b) and Foreign Pension Plans
Article:
Cross-border transfers of employees affect their pension plans and other deferred compensation arrangements. In some of these instances, some or all of the amounts may be subject to U.S. taxation.
Published on March 18, 2013
U.S. Sandwich Structures in the International Inbound Context
Article:
When a foreign multinational operates in the United States through a U.S. group that has underlying foreign operations—a “U.S. sandwich structure”—repatriating the U.S. group’s foreign earnings often results in tax inefficiencies.
Published on March 18, 2013
Family Investment Partnerships All the Perks
Article:
Family investment partnerships are frequently used to manage and control multigenerational family wealth and may result in significant economic and tax benefits.
Published on March 18, 2013
Application of the Tax Basis and At-Risk Loss Limitations to Partners
Article:
Individual partners who have been allocated a distributive share of loss must satisfy three separate loss limitations before the loss can be used.
Published on March 18, 2013
When Is Form 8283 Required to Be Filed
Article:
The IRS should revise the instructions for Form 8283 to more clearly explain when it is required to be filed, given that the instructions state that failure to file the form can cause the deduction to be disallowed in its entirety.
Published on March 18, 2013
IRS Chief Counsel Continue Applying Valuation Misstatement Penalties
Article:
The IRS recently addressed the application of the valuation misstatement penalties contained in Secs. 6662(b)(3) and 6662(h).
Published on March 18, 2013
Individual Taxation Developments
Article:
This article covers recent developments affecting individual taxation. The items are arranged in Code section order
Published on March 18, 2013
Assisting the Newly Widow[er]ed
Article:
This article discusses ways to aid clients who have suffered the loss of a spouse or other close loved one.
Published on March 18, 2013
Preserving Tax Losses by Avoiding the Wash-Sale Rules
Article:
A taxpayer cannot deduct the loss realized on the sale of stock or securities (including shares in a mutual fund) if the taxpayer purchases substantially identical stock or securities within the period beginning 30 days before and ending 30 days after the sale.
Published on February 29, 2012
IRS Proposes New Equitable Innocent Spouse Relief Rules
Article:
The IRS issued a proposed revenue procedure changing the way it will treat requests for equitable innocent spouse relief under Secs. 66(c) and 6015(f).
Published on February 29, 2012
Third Offshore Voluntary Disclosure Program Launched
Article:
The IRS announced it was starting a third offshore voluntary disclosure initiative (OVDI) designed to help people with unreported offshore accounts get current with their taxes in the United States.
Published on February 29, 2012