Statute of Limitation Individuals and U.S.-Source Income
This item describes some of the unusual situations that arise under federal income tax statutes of limitation.
Published on October 01, 2011
Court Rules on Sale of Ownership Rights in Insurance Company Demutualization
Applying the open transaction doctrine, the Court of Federal Claims held that a trust was entitled to a refund of taxes paid on the proceeds of the sale of stock the trust received in exchange for its ownership rights in a mutual life insurance company when the company was demutualized.
Published on October 01, 2010
Large Business and International Examination Process Changes
The IRS Large Business and International (LB&I) Division has focused on improving the quality, efficiency, and effectiveness of the overall compliance and examination process for LB&I taxpayers.
Published on January 01, 2012
2012 Arthur J. Dixon Memorial Award
Alan R. Einhorn, CPA, received the 2012 Arthur J. Dixon Memorial Award.
Published on January 01, 2013
AICPA News Update Vol. 14 No. 9
1099 Repeal Bill Passed by the House of Representatives
Published on March 04, 2011
AICPA News Update Vol.12 No.28
Vote on Consumer Financial Protection Agency Delayed Until September; AICPA Joins Chamber of Commerce and Others Urging More Time, AICPA, GAA Host Roundtable for Accounting Leaders to Discuss Simplifying Financial Reporting, What Government Entities Need to Know about American Reinvestment and Recovery Act of 2009; New Member Resource Online for
Published on June 24, 2011
LMSB Identifies New Repairs Issue
In an IRS Large and Mid-Size Business (LMSB) Division memorandum (LMSB-4-0509-019), the IRS notified LMSB executives of an emerging issue relating to the recharacterization of costs associated with tangible assets previously capitalized under Sec. 263(a) as currently deductible repairs under Sec. 162.
Published on January 01, 2010
AICPA Tax Standards Strengthened
Revised AICPA statements on standards for Tax Services (SSTS) became effective on January 1, 2010, and provide high, enforceable ethical responsibilities for CPAs in providing tax services.
Published on February 01, 2010
Certain Debt Obligations Not Subject to AHYDO Restrictions
As a result of the recent deteriorating market conditions for debt obligations, the IRS has indicated that it will not regard specific debt obligations as applicable high-yield discount obligations (AHYDO) for purposes of Secs. 163(e)(5) and 163(i).
Published on December 01, 2008
Tax Practice Quality Control
Practitioners should consider implementing a tax practice quality-control system.
Published on November 01, 2012