IRS Issues Technical Advice on Success-Based Fees

Article:  When a taxpayer incurs success-based fees, the determination of whether the fees are currently deductible, as opposed to capitalizable, depends on whether the taxpayer can establish contemporaneously that all or a portion of the fees...
Published on January 28, 2011

Ten Things CPAs Need to Know About Structured Legal Fees

Article:  With the right preparation, a structured legal fee agreement can be an excellent tax planning tool for plaintiffs’ lawyers
Published on May 10, 2010

Ninth Circuit Awards Litigation Costs Paid by Third Party

Article:  The Ninth Circuit reversed the Tax Court and held that a taxpayer could “incur” attorneys’ fees initially paid by a third party for purposes of an award of litigation costs under Sec. 7430
Published on January 28, 2011

Code of Professional Ethics

Article:  Our ethical behavior is essential to preserve the trust that the public has placed in our profession. The publicity on certain isolated individuals within our profession has, at times, left a doubt with the public that we must attempt to dispel. We as professionals must double our efforts to make
Published on January 28, 2011

AICPA News Update - May 4, 2012

Newsletter:  In this issue: USDA Requiring CPAs to Attest to AGI Limitations for Clients in Certain Farming Programs, AICPA Submits Comment Letter on PCAOB Broker-Dealer Proposal, Regulatory Alert: SEC Independence Requirements Apply to Auditors of Nonissuer Broker-Dealers and Investment Advisers, CGMA Report Provides Guidance for Transforming the Finance Organization, TPA Issued on Compilation and Review
Published on May 08, 2012

New Rules Govern Practice Before the IRS

Article:  Editor: Joel E. Ackerman, CPA, MST The highly publicized accounting scandals of 2002, such as Enron, WorldCom, and Global Crossing, along with revelations about tax shelter abuses, have had wide-reaching financial effects on investors and the economy. Act
Published on April 19, 2010

Tax Practice Quality Control

Article:  Practitioners should consider implementing a tax practice quality-control system.
Published on October 31, 2012

Regulation of Tax Return Preparers

Article:  To improve the oversight of tax preparation by paid tax preparers, the IRS has established a registration, examination, and continuing education regime for paid tax preparers. This article discusses the general requirements under the regime and the specific rules and exceptions to the rules for CPAs.
Published on May 01, 2011

Nonrefundable Milestone Fees Do Not Qualify as Success-Based

Article:  A business can expense 70% of “success-based fees,” meaning amounts that are contingent on the successful closing of a covered transaction. It is important to remember this safe-harbor election can apply to both sides of the transaction
Published on November 30, 2012

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...
Published on July 22, 2010

LB&I Directive on Success-Based Fees Has Tax Accounting Implications

Article:  A recent directive instructs LB&I examiners not to challenge the treatment of success-based fees incurred or paid in tax years ending before April 8, 2011, if the taxpayer capitalized at least 30% of the total success-based fees incurred on the transaction on...
Published on August 24, 2012

IRS Addresses Treatment of M&A Transaction Costs and Success-Based Fees

Article:  Taxpayers that incur costs relating to an acquisition or restructuring transaction must generally capitalize the costs that “facilitate” the transaction.
Published on May 31, 2013

Tax Treatment of Payments in Common Pharmaceutical Agreements

Article:  The Service outlined its position on the treatment of the various types of payments under pharmaceutical collaboration agreements in a coordinated issue paper.
Published on May 02, 2010

On the Bookshelf

Article:  Books of interest to tax practitioners.
Published on January 28, 2011

Circular 230 Its Day-to-Day Impact on Tax Practices

Article:  ...standards it imposes relating to tax returns and opinions, the breadth and scope of Circular 230 also regulates the day-to-day business operations of tax practitioners relating to fees, client solicitations, marketing and advertising, and the management of client files and records
Published on August 24, 2012