Concerns About CPA Letters to Third Parties

Article:  A CPA receives a request from a client to provide a letter to the client’s mortgage broker, lender, adoption agency, or other third party. Is there any harm in the CPA signing the client’s suggested letter or writing one...
Published on May 14, 2010

AICPA News Update - July 27, 2012

Newsletter:  In this issue: Comments Submitted to IRS on Accounting Method for Income from Gift Card Receipts, AICPA Signals Support for Fraudulent Tax Preparer Fraud Penalties to House Tax Committee, Remember to Renew Your Membership by July 31, Health Care Expert Panel Develops TPA on Accounting for Costs Incurred During ICD-10 Implementation, Accounting and
Published on September 07, 2012

Safe-Harbor Lookthrough Treatment for RIC Investments in PPIPs

Article:  The IRS has outlined a safe harbor for regulated investment companies (RICs) for purposes of the Sec. 851(b)(3) asset diversification tests that treats a RIC as if it directly invested in the assets held by a publicprivate investment partnership (PPIP) in which it invests.
Published on January 28, 2011

Ordinary Worthless Stock Deductions Characterizing Subsidiary Receipts

Article:  An ordinary loss deduction for worthless stock of an affiliated operating subsidiary generally is permitted as long as more than 90% of the subsidiary’s gross receipts are from active operating income. This item discusses the difficulty of determining whether a subsidiary’s gross receipts qualify as active operating income for this purpose
Published on October 04, 2011

Flexibility for Intragroup Restructuring and Asset Transfers

Article:  Letter Ruling 201127004 reinforces the flexibility granted to taxpayers wishing to move assets around a qualified group without triggering gains or meeting the stringent qualifications of Sec. 355
Published on March 18, 2013

International Tax Compliance for Auditors and CFOs

Article:  In an environment where international tax examinations will play a larger role in tax audits, prudent financial executives and auditors will take the time to evaluate their current international tax compliance, assess any shortcomings, and correct them.
Published on January 28, 2011

Significant Recent Developments in Estate Planning

Article:  This article examines developments in estate, gift, and generation-skipping transfer tax planning and compliance between June 2008 and May 2009.
Published on January 28, 2011

Sec. 382 Ownership and Fluctuation in Value

Article:  For a corporation with more than one class of stock, the effects stock price fluctuations can play a significant role in determining whether use of the NOLs could become limited as a result of trading and other equity shifts.
Published on May 02, 2010

When Plaintiffs in Class Actions Pay Tax on Attorneys Fees

Article:  The taxation of attorneys’ fees in opt-out class actions has become relatively clear, as long as certain elements are established. In opt-in cases, class members risk being tagged with income in the amount of the attorneys’ fees.
Published on July 22, 2010

S Corporation Sale of Assets Followed by a Liquidation

Article:  This item focuses on the specific tax implications to the seller of the sale of an S corporation's assets followed by a liquidation or a deemed asset sale followed by a liquidation.
Published on March 11, 2011

Revenue Procedure Attempts to Clarify Entity Classification Election

Article:  For federal tax purposes, certain entities can elect passthrough tax treatment by simply checking the box. As this item points out, checking the box for passthrough treatment is not so simple if the taxpayer is uncertain about whether the entity has more than one member.
Published on October 04, 2011

Individual Taxation Report Recent Developments

Article:  This article covers recent developments affecting the taxation of individuals, including health care reform and other legislation, regulations, cases, and IRS guidance. The items are arranged in Code section order.
Published on January 28, 2011

Current Developments in Employee Benefits and Pensions (Part II)

Article:  Though 2009 featured big changes in Washington and severe challenges for plan sponsors, the year brought largely incremental changes for qualified defined benefit and defined contribution plans as the IRS and the Department of Labor (DOL) continued to interpret recent statutory guidance and Congress provided some measures of relief.
Published on January 28, 2011

Significant Recent Developments in Estate Planning (Part II)

Article:  This article covers gift tax, generation-skipping transfer (GST) tax, trust developments, and the annual inflation adjustments for 2011 relevant to estate and gift tax.
Published on April 17, 2012

Schedule UTP IRS Mandates Disclosure of Uncertain Tax Positions

Article:  This article explores the requirements of Schedule UTP, discusses modifications to the IRS’s policy of restraint pertaining to tax reconciliation workpapers, and suggests how to avoid the inadvertent waiver of the work-product privilege for documents relating to uncertain tax positions.
Published on April 20, 2012