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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

    New Decanting Statutes Offer Road Map for Escaping Fiduciary Tax and Updating Trust Terms

    Article As trust decanting statutes proliferate, federal and state taxing authorities must wrestle with the income, estate, and gift tax issues raised by decanting
    Published on April 01, 2013

    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

    Tax Practice Responsibilities

    Article This new quarterly column addresses the tax practice responsibilities part of CPA tax professionals’ practice and provides information that will enable practitioners to become better informed about and meet their legal, regulatory, and ethical responsibilities as...
    Published on July 20, 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

    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 January 28, 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

    Analyzing the Tax Implications of Grants Received for Investment Tax CreditEligible Property

    Article The recent availability of grants in lieu of the production tax credit (Sec. 45) and the investment tax credit (Sec. 48) has become a well-documented source of funding for the installation of certain energy property
    Published on July 13, 2012

    IRS Taking Firm Approach to Ozone-Depleting Chemical Excise Tax Compliance

    Article The IRS has recently reinvigorated its examination of the ozone-depleting chemicals tax, adopted a strict interpretation of the regulations, and instituted a laboratory testing program to detect ODCs in printed circuit boards
    Published on January 28, 2011

    Portability of Unused Estate and Gift Tax Exclusion Between Spouses

    Article One of the essential elements in the equation for the computation of both the federal gift and estate tax is the reduction of the tax due by the amount of the estate or gift tax on the applicable exclusion amount. Because of changes to the tax law, a...
    Published on July 20, 2011

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