IRS Issues New Rules on Allocation of Partnership Items
Proposed regulations under Sec. 704(c) provide that the Sec. 704(c) anti-abuse rule takes into account the tax liabilities of both the partners in a partnership and certain direct and indirect owners of such partners.
Published on August 01, 2008
IRS Issues Partnership Anti-Abuse Rule Regs.
The IRS and Treasury issued final regulations on June 8 to provide that the Sec. 704(c) anti-abuse rule takes into account the tax liabilities of both partners and certain owners of partners (T.D. 9485). The regulations also provide that partnerships cannot use an allocation method to achieve tax results that
Published on August 01, 2010
Revised Form 990 The Evolution of Governance and the Nonprofit World
The revised Form 990, Return of Organization Exempt from Income Tax, incorporates many of the same governance principles and transparency best practices introduced to the for-profit world through the Sarbanes-Oxley Act.
Published on August 01, 2009
Reporting Uncertain Tax Positions to the IRS
On January 26, 2010, the IRS issued Announcement 2010-9, indicating that it intends to require certain corporate taxpayers to disclose information about their uncertain tax positions on their tax returns.
Published on May 01, 2010
New Rules Govern Practice Before the IRS
...Editor: Joel E. Ackerman, CPA, MST The highly publicized accounting scandals of 2002, such as Enron, WorldCom, and Global Crossing, along with revelations about tax shelter abuses, have had wide-reaching financial effects on investors and the economy. Act
Published on October 01, 2007
Deducting Losses for Defrauded Investors
This article considers theft losses “incurred in an activity engaged in for profit.” These investment theft losses are not subject to the 10% of AGI reduction for losses of personal use property, the 2% of AGI floor for miscellaneous itemized deductions, or the itemized deduction phaseout rules of Sec. 68.
Published on July 01, 2009
Debt Modifications for Employees Does Sarbanes-Oxley Nullify Rev. Rul. 2004-37
This item discusses the prohibition on loans and loan modifications in SOX and the tax consequences of loan modifications in Rev. Rul. 2004-37.
Published on November 01, 2008
FIN 48 Compliance Disclosing Tax Positions in an Age of Uncertainty
FIN 48 presents new challenges for taxpayers, auditors, and tax advisers. The disclosures required by the interaction of FAS 109 and FIN 48 will result in greater public disclosure of tax planning techniques, including the strengths and weaknesses of those techniques.
Published on January 01, 2008