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July

The Tax Adviser July 2012 

Articles

Taxing the Transfer of Debts Between Debtors and Creditors
Edward J. Schnee and W. Eugene Seago

Deducting Employee MBA Expenses
Joseph Medina and Stephen LaGarde

Sales Tax Audit Best Practices
Theresa Esparza, Jennifer Jensen, and Alesia Parfiryeva

 

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Deducting Employee MBA Expenses

Article The deductibility of the cost of an MBA degree under Sec. 162(a) as a trade or business expense for an employee is a complex subject, with several factors to consider.
Published on August 09, 2012

Contributing to a Childs IRA

Article Establishing an IRA in a child’s name can be an effective planning technique for a child with earned income.
Published on August 09, 2012

The Tax Adviser July 2012

Publication Articles Taxing the Transfer of Debts Between Debtors and Creditors Edward J. Schnee and W. Eugene Seago Deducting Employee MBA Expenses Jose
Published on July 02, 2012

Increased Focus on International Activities of Tax-Exempt Organizations

Article Many tax-exempt entities participate in the global economy by engaging in charitable or other exempt activities overseas and making foreign financial investments; These activities have drawn attention from the IRS as they examine the flow of tax-exempt funds around the world.
Published on June 30, 2012

Preparing for the Medical Device Excise Tax

Article Taxpayers may face a number of unresolved issues in preparing to comply with the new excise tax on sales of medical devices.
Published on June 30, 2012

Employment Tax Liabilities of Foreign Entities

Article A number of technical questions are involved in determining status as an employer for federal employment tax purposes when a foreign business sends individuals to work in the United States.
Published on June 30, 2012

Using Sec. 338 to Avoid Antichurning Rules

Article When assets are sold in a taxable transaction, the buyer must be aware of limitations placed on amortizing certain acquired intangibles under the antichurning rules; a recent ruling highlights the ability to use a Sec. 338 election to create the effect of an asset sale while avoiding the antichurning rules.
Published on June 30, 2012

FIRPTA Notice Requirements for Property Acquired in Foreclosure Sale

Article Parties involved in the disposition of a U.S. real property interest as the result of a repossession of or foreclosure on the property need to be aware of their ) withholding requirements, as well as the availability of alternative withholding and notice requirements for foreclosure dispositions.
Published on June 30, 2012

Combined Reporting Creates Compliance Challenges

Article An increasing number of states have enacted or proposed combined reporting requirements for related entities involved in a unitary business, creating increased compliance burdens for taxpayers and administrative challenges for state tax agencies.
Published on June 30, 2012

Homeland Security May Contact U.S. Persons Living Abroad Who Owe Back Taxes

Article The IRS has established procedures to facilitate tax collection from taxpayers who live outside the United States, including submitting identifying taxpayer information to a database maintained by the Department of Homeland Security.
Published on June 30, 2012

Post-Deal Depreciation Impact of Certain Nonrecognition Transactions

Article When planning an incorporation or reorganization transaction, taxpayers and their advisers may not examine in depth the related accounting method and depreciation issues that arise as a result of the transaction.
Published on June 30, 2012

Issues Facing Partnerships Under FIRPTA

Article This item identifies several issues taxpayers should be aware of to the extent they invest in partnership structures that hold U.S. real property interests.
Published on June 30, 2012

Interaction of the Subpart F Dual-Character Property and Majority-Use Rules

Article When a controlled foreign corporation (CFC) sells property used in its active business, any gain generally is not treated as subpart F income includible in its U.S. shareholders’ taxable income.
Published on June 30, 2012

Potential Pitfalls in PFIC Reporting

Article PFIC investors should be aware of new PFIC reporting requirements and should be alert to developments that may affect them.
Published on June 30, 2012

Federal Income Tax Treatment of Certain Transferable State Tax Credits

Article The emergence of online marketplaces and auction houses has provided a single point of contact for both sellers and buyers, making sales and purchases of transferable state tax credits more common.
Published on June 30, 2012

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