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    Defending R&D Credits

    Article This article highlights and analyzes some recent decisions concerning the research and development (R&D) tax credit and IRS administrative practices when auditing R&D credit claims, most notably the Union Carbide decision in the Tax Court
    Published on May 01, 2010

    IRS Increases Focus on Tax Hedge Identification Rules

    Article The IRS recently signaled its increasing interest in the tax treatment of hedging transactions, particularly with regard to proper taxpayer identification
    Published on May 01, 2011

    Reporting Uncertain Tax Positions to the IRS

    Article 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

    States Examining Business Tax Incentives

    Article It is well known that states use their tax systems as an economic development tool for attracting and retaining businesses. Competition among the states to attract businesses is sometimes called a "race to the bottom." States are frequently...
    Published on June 24, 2010

    Tax Court Again Holds That Innocent Spouse Relief Limit Is Invalid

    Article Despite being overruled by the Seventh Circuit in an earlier case, the Tax Court has again held that the regulatory two-year limitation period for filing a claim for equitable innocent spouse relief under Sec. 6015(f) is invalid. This item assesses...
    Published on November 01, 2010

    Death and Taxes Executors Beware

    Article The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act revised tax law for estates of decedents dying in 2010, 2011, or 2012. The new rules apply for 2010 unless an...
    Published on April 01, 2011

    Foreign Disregarded Entities May Face U.S. FICA Tax Issue

    Article This item shows how restructuring international businesses to operate through entities disregarded for U.S. federal income tax purposes may also affect the employment tax treatment of the organization’s individual employees
    Published on June 01, 2011

    Are You Properly Paying the Ozone-Depleting Chemicals Excise Tax

    Article In recent years, IRS excise tax examinations have focused on taxpayers that import articles potentially subject to the excise tax imposed on certain ozone-depleting chemicals (ODCs) under Sec. 4681
    Published on June 01, 2010

    IRS Proposes New Tax Return Preparer Standards

    Article The IRS released a list of recommendations calling for the registration, testing, and continuing education of currently unregulated tax return preparers
    Published on May 01, 2010

    When Is a U.S. LLC a Partnership for U.S. and U.K. Tax Purposes

    Article ...the United States as a partnership. This item examines how profits and losses of a U.S. LLC will be taxed on a U.K. resident’s U.K. tax return
    Published on August 01, 2011

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