Determining Tax Consequences of Corporate Liquidation to the Shareholders
Article:
Under Sec. 331, a liquidating distribution is considered to be full payment in exchange for the shareholder’s stock, rather than a dividend distribution, to the extent of the corporation’s earnings and profits.
Published on October 11, 2012
What Can One Line Do for You
Article:
One area where many CPA practitioners can consider offering expanded services is in personal financial planning.
Published on September 28, 2012
Guidance on Foreign Tax Credit Splitter Transactions
Article:
Treasury published temporary regulations to provide guidance on the Sec. 909 foreign tax credit splitter event provisions that were enacted in August 2010.
Published on August 31, 2012
Temporary Regulations Create New Applications for Cost-Segregation Studies
Article:
Owners of real estate should consider the implications of the new regulations regarding tangible property and repair costs when engaging firms to perform cost-segregation studies.
Published on August 31, 2012
Corporate Financing Companies Treatment of Losses
Article:
Financial blocker entities are used as a mechanism to prevent funds from potentially being engaged in a U.S. trade or business.
Published on August 31, 2012
New Foreign Asset Reporting Rules
Article:
Practitioners need to be aware of the new requirements for reporting foreign assets and income and confirm that clients are complying.
Published on August 31, 2012
Deducting Losses on Worthless Investment Securities
Article:
Understanding the rules for deducting losses on worthless securities is necessary to determine the correct timing of the loss deduction.
Published on August 31, 2012
Whats New With the New Markets Tax Credit
Article:
The IRS published final regulations relating to how an entity serving targeted populations can meet the requirements to be a qualified active low-income community business under the provisions of the new markets tax credit program.
Published on August 31, 2012
Deductibility of LEED Certification Costs
Article:
Tax professionals may be in the best position to support their clients or company in identifying LEED certification costs and determining the appropriate tax treatment as either a current-period expense or a capital expenditure.
Published on August 31, 2012
Successor Liability for State Income and Franchise Taxes
Article:
A small but important group of states that provide a statutory basis for imposing on a purchaser of assets liability for income taxes owed by the seller.
Published on August 31, 2012
A Cautious Approach to Sec. 163(l) in Common Private-Equity Lending
Article:
Fund financing can carry with it the potential for unintended tax consequences under Sec. 163(l)’s “disqualified debt” rules.
Published on August 31, 2012
REITs May Treat Money Market Funds as a Cash Item
Article:
Rev. Rul. 2012-17 confirms that a real estate investment trust (REIT) may treat shares it holds in a money market fund as cash for purposes of meeting the qualifying asset tests of Sec. 856(c)(4)(A).
Published on August 31, 2012
The Codified Economic-Substance Doctrine and Captive Insurance Companies
Article:
In light of the lack of guidance on whether the new codified economic-substance rules apply to captive insurance companies, it is prudent to assume that the law does apply.
Published on August 31, 2012
A Practical Approach to Sales Taxes in the Cloud
Article:
An approach to analyzing the sales and use tax implications of a purchase on the cloud.
Published on August 31, 2012
Guidance Distinguishes Tips and Service Charges
Article:
The IRS issued question-and-answer guidance for distinguishing between tips and service charges for FICA tax and other purposes.
Published on August 31, 2012