June

    The Tax Adviser June 2013 

    Photo by Getty Images/Comstock/Thinkstock Articles

    Targeted Partnership Allocations: Part I
    Noel P. Brock

    Advising Clients Regarding Erroneous Tax Return Positions: Part I
    Michael E. Baillif

    Dealing With the Secondary U.S. Tax Consequences of Transfer-Pricing Adjustments
    James M. Hill

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    The Tax Adviser June 2013

    Publication Articles Targeted Partnership Allocations: Part I Noel P. Brock Advising Clients Regarding Erroneous Tax Return Positions: Part I Michael E. Ba
    Published on September 16, 2013

    Identifying and Making LLC Elections

    Article As a separate taxable entity, an LLC has the ability to make certain tax elections like any other taxpayer.
    Published on July 01, 2013

    Sec. 108(e)(2) and Debt That Would Give Rise to Basis

    Article A taxpayer is not required to recognize taxable income for the discharge of a liability when payment of the liability would have given rise to a tax deduction.
    Published on May 31, 2013

    Tax Accounting Methods for Small Businesses

    Article There are several simplifying conventions and accounting methods tailored to smaller business entities that can sometimes result in tax savings and streamline the tax return preparation process and recordkeeping requirements.
    Published on June 01, 2013

    The Proposed Statement on Standards in Personal Financial Planning What Does It Mean for You

    Article To adapt to this rapidly evolving area of practice, the AICPA released this spring an exposure draft of the Proposed Statement on Standards in Personal Financial Planning Practice.
    Published on June 01, 2013

    Targeted Partnership Allocations Part I

    Article This article discusses the rules governing safe-harbor allocations, the rules governing targeted allocations, and reasons for the use of targeted allocations.
    Published on June 01, 2013

    Suspension of Tangible Property Capitalization Issue Examinations Extended

    Article The IRS posted an updated directive for field examinations on the repair vs. capitalization issue that extends the suspension of examinations.
    Published on June 01, 2013

    New York Court of Appeals Upholds Amazon Law

    Article New York’s highest court has confirmed that New York residents have to pay sales tax on internet sales where the vendor’s only contact with the state is through in-state affiliates.
    Published on June 01, 2013

    Asset Transfers to Foreign Corporations

    Article The IRS issued final, temporary, and proposed regulations governing outbound asset transfers under Sec. 361.
    Published on June 01, 2013

    Taxation of the Cloud Still Hazy

    Article This column updates readers on some recent state guidance on cloud service offerings and highlights a few examples of the trends appearing at the state level.
    Published on June 01, 2013

    Tax Court Reverses Its Position on Valuation Misstatement Penalty Supreme Court Agrees to Hear Case on the Issue

    Article The Tax Court held that a taxpayer may not avoid application of the gross valuation misstatement penalty by conceding that adjustments made in an IRS FPAA notice were correct on grounds unrelated to valuation or basis.
    Published on June 01, 2013

    How to Identify a Potential Criminal Tax Matter Requiring an Attorney

    Article This column discusses some of the circumstances where it might be appropriate to refer or involve an experienced criminal tax attorney and the importance of making a timely referral.
    Published on June 01, 2013

    Dealing With the Secondary U.S. Tax Consequences of Transfer-Pricing Adjustments

    Article This article explains how a transfer-pricing adjustment triggers secondary financial consequences in a multinational group.
    Published on June 01, 2013

    Appeals Court Refuses to Lift Injunction in Return Preparer Regulation Case

    Article The IRS lost another round in its court battle over its plan to regulate tax return preparers when the D.C. Circuit denied its motion to stay an injunction halting the IRS’s return preparer regulation program.
    Published on June 01, 2013

    Promoting Fictitious Bonds for Tax Payments Leads to Conviction for Sovereign Citizen

    Article A proponent of the “sovereign citizens” movement has been convicted of conspiracy to defraud the United States through a series of seminars in which attendees were taught to pay their federal income taxes by filing fictitious bonds.
    Published on June 01, 2013

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