The Tax Adviser October 2012 


    New LB&I Knowledge Management Strategies: IPGs and IPNs
    Robert D. Adams

    Current Developments in S Corporations
    Stewart S. Karlinsky and Hughlene Burton

    U.S. LLCs for U.K. Tax Purposes
    Rob Whittall

    Recent Developments in Estate Planning: Part II
    Justin P. Ransome and Frances Schafer



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    U.S. LLCs for U.K. Tax Purposes

    Article What are the global tax implications for LLC members who are not U.S. residents?
    Published on October 23, 2013

    New LB&I Knowledge Management Strategies IPGs and IPNs

    Article Issue practice groups and international practice networks represent a new strategy the LB&I Division to pool and perpetuate institutional expertise.
    Published on October 31, 2012

    Final Regs. Issued on Entertainment Use of Business Aircraft

    Article The IRS issued final regulations relating to the disallowance under Sec. 274 of deductions for the use of business aircraft for entertainment (T.D. 9597).
    Published on September 30, 2012

    Taxpayer Cannot Revive Equitable Innocent Spouse Claim

    Article A U.S. District Court dismissed a taxpayer’s claim that she was entitled to innocent spouse relief under Notice 2011-70, which announced the removal of the two-year limitation period for claims for equitable innocent spouse relief under Sec. 6015(f).
    Published on September 30, 2012

    Prop. Regs. Clarify Who Is Subject to Limit on Meal and Entertainment Expenses

    Article The IRS released proposed regulations clarifying which party is subject to the rule that limits the deduction for meals and entertainment to 50% of the expenses incurred.
    Published on September 30, 2012

    Recent Developments in Estate Planning Part II

    Article This article covers recent developments in estate tax, including the portability election, proposed regs. on the alternate valuation date, FLPs.
    Published on September 30, 2012

    Model Intergovernmental FATCA Agreements Released Draft Form Posted

    Article The Treasury Department released a model intergovernmental agreement designed to implement the information-reporting and withholding-tax provisions of FATCA.
    Published on September 30, 2012

    IRS Permits Charitable Contributions to Single-Member LLCs

    Article The IRS explained that contributions to disregarded SMLLCs wholly owned and controlled by a U.S. charity will be treated as if made directly to the U.S. charity.
    Published on September 30, 2012

    Watch for Further IRS Pronouncements on ITINs

    Article The AICPA has voiced concerns to the IRS about the Service’s interim rules that foreign nationals must generally include original documentation with Form W-7, Application for IRS Individual Taxpayer Identification Number.
    Published on September 30, 2012

    Taxpayer Liable for Willful Violation of FBAR Requirements

    Article The Fourth Circuit held that a taxpayer had willfully violated the foreign bank account reporting requirements for two foreign bank accounts.
    Published on September 30, 2012

    Taxpayers Not Insolvent for Purposes of Sec. 108 Exclusion

    Article The Tax Court held that a married couple had failed to prove the FMV of their two homes and the husband’s pension and thus could not prove they were insolvent.
    Published on September 30, 2012

    LLC Distributions of Contributed Property

    Article An LLC member who makes a contribution to the LLC of property with an FMV different from its basis may be required to recognize gain or loss upon a subsequent distribution of the contributed property to another member.
    Published on September 30, 2012

    Setting Up Firm Procedures to Fight Identity Theft

    Article Ways tax professionals can help combat identity theft and educate their clients.
    Published on September 30, 2012

    Current Developments in S Corporations

    Article During the period of this S corporation tax update, some major changes that directly affect S corporations took place. This article also presents tax planning ideas for S corporations and their shareholders.
    Published on September 30, 2012

    IRS Issues Blueprint for IC-DISC Audits

    Article The IRS released its advanced audit guide for agents involved in examinations of IC-DISCs.
    Published on September 30, 2012

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