Trust Deductions Knight, Prop. Regs. Still Govern
Article:
Preparers of fiduciary tax returns for tax years 2011 and 2012 will not be required to unbundle fiduciary fees, but they still must treat payments readily identifiable as subject to the 2% floor separately from a bundled fiduciary fee.
Published on May 25, 2012
FBAR Handle With Care
Article:
Failing to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), can result in severe civil and/or criminal penalties.
Published on May 16, 2012
Tangible Property Regulations
Article:
The IRS recently released the long-awaited tangible property regulations, commonly referred to as the “repair” regulations.
Published on May 11, 2012
Sec. 6045B Reporting Requirements
Article:
Sec. 6045B requires an issuer of a specified security to report certain information to the IRS and to its shareholders following an organizational action that affects the basis of a specified security.
Published on April 30, 2012
Opportunities for Incorporating International Tax Law Into All Levels of the Tax Curriculum
Article:
Considering the global nature of today’s businesses, covering international topics is necessary at all levels of the business curriculum.
Published on April 30, 2012
Benefiting From Unique Attributes of ESOPs
Article:
An employee stock ownership plan (ESOP) is a stock bonus plan or a combination of a stock bonus plan and money purchase pension designed to invest primarily in stock of the employer.
Published on April 30, 2012
The Research Credit and Deduction for Passthrough Entities
Article:
Passthrough entities may be overlooking the research tax credit because they are not aware that they are engaged in eligible activities, do not think their activities are qualified, or do not believe they can meet the various requirements.
Published on April 30, 2012
Intercompany Debt in a Deemed Asset Sale Election
Article:
This item discusses IRS guidance illustrating the impact of extinguishment of intercompany debt immediately preceding a Sec. 338(h)(10) election.
Published on April 30, 2012
Post-Implementation Review of FIN 48
Article:
The Financial Accounting Foundation issued its Post-Implementation Review (PIR) Report on FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes.
Published on April 30, 2012
LB&I Guidance on Benefits-and-Burdens-of-Ownership Analysis Under Sec. 199
Article:
The IRS LB&I Division issued guidance to field examiners in determining whether a taxpayer conducting production activities under a contract manufacturing arrangement with an unrelated third party meets the benefits-and-burdens-of-ownership requirement outlined in the domestic production activities deduction rules under Sec. 199.
Published on April 30, 2012
Guidance Issued on Interest Exceeding Acquisition and Home Equity Indebtedness Limitations
Article:
The IRS recently released guidance for allocating excess mortgage interest expense.
Published on April 30, 2012
Removal of Sec. 163(j) Limitation Does Not Qualify as Accounting Method Change
Article:
The IRS concluded that removing the Sec. 163(j) limitation on the deduction of interest paid on a loan from a related party does not qualify as an accounting method change under Sec. 446.
Published on April 30, 2012
Final Partnership Debt-for-Equity Regulations
Article:
The IRS issued final regulations that provide guidance on the recognition of discharge of indebtedness income in partnership debt-for-equity transfers.
Published on April 30, 2012
Accuracy-Related Penalty Tested in Five Recent Cases
Article:
In five recent cases, the Tax Court tested the defenses of various taxpayers to the imposition by the IRS of accuracy-related penalties for substantial understatements of income tax.
Published on April 30, 2012
Are Taxpayers Bound by Purchase Price Allocations
Article:
A recent Tax Court opinion highlights the importance of preacquisition planning with respect to agreed-upon purchase price allocations in asset acquisition agreements under Sec. 1060.
Published on April 30, 2012