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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 January 28, 2011

    Controlling Interest Provisions in State and Local Real Estate Transfer Taxes

    Article A common way for a taxpayer to transfer real estate to a new owner without paying a real property transfer tax has been to transfer an ownership interest in an entity that holds title to the property. However, a number of jurisdictions now require taxpayers who engage in these types...
    Published on January 13, 2012

    Potential Implication of Recent Sec. 469 Court Decisions for Self-Employment Tax Rules

    Article For purposes of self-employment taxes, many members of LLCs have treated themselves as limited partners and have therefore reported that their distributive share of income was not subject to self-employment tax under Sec...
    Published on January 28, 2011

    Final Form and More Guidance on Small Business Health Care Tax Credit

    Article The IRS released a new form and guidance relating to the small business health care tax credit for the 2010 tax year. The guidance discusses issues relating to employers’ eligibility for the credit and other eligibility issues
    Published on February 01, 2011

    Sale Versus Loan A Current Development in Tax Ownership

    Article The characterization of a transaction as a sale has significant tax implications. The Calloway case rules on if and when a taxpayer sold his stock upon entering into an agreement, which purported to be a nonrecourse loan. This item summarizes...
    Published on February 01, 2011

    Comparing International Tax Systems in the Introductory Tax Class

    Article This column describes an assignment that requires a modest time commitment to bring international tax issues into the introductory tax course and to raise student awareness of differences in tax systems
    Published on November 02, 2010

    Tax Return Preparers Win Partial Victory in Fraudulent Credit Scheme Case

    Article A district court found that two tax return preparers who had participated in a fraudulent scheme involving credits for fuel from nonconventional sources did not know the scheme was fraudulent and dismissed the IRS’s requests...
    Published on November 30, 2011

    Tax Increases Contained in State Ballot Initiatives Soundly Rejected

    Article On November 2, 2010, the midterm elections featured several ballot initiatives dealing with state tax matters. In most instances, voters rejected initiatives to the extent that they would raise taxes, implicitly requesting that their governments look for alternative means to solve their states’ budget...
    Published on February 01, 2011

    Reporting Uncertain Tax Positions

    Article This item explores the differences between financial statement reporting and federal income tax return disclosure in preparing for disclosure of uncertain tax positions on the Schedule UTP
    Published on June 16, 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 January 28, 2011

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