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Selling a Business Substance and Form Really Do Count

Article Three concepts regularly come into play when contemplating the sale of a business: noncompete covenants, consulting agreements, and goodwill
Published on March 11, 2011

Personal Intangibles The Antichurning Rules

Article In the process of selling the business of a closely held C corporation, the concept of the sale of personal intangibles should be considered in structuring the transaction
Published on January 28, 2011

The Partnership Technical Termination Trap

Article A sale or exchange of 50% or more of the total interest in a partnership’s capital and profits within a 12-month period causes the tax year of the partnership to close.
Published on September 30, 2012

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

Partner Allowed to Make Different Elections for Different Partnership Interests

Article The Tax Court held that taxpayers owning multiple interests in the same partnership were entitled to make different elections under Sec. 6223 for each interest.
Published on May 03, 2010

Is the Sale of Real Property Ordinary Income or Capital Gain

Article Determining whether a real estate sale produces ordinary income or capital gain is difficult and is potentially an issue that can cause a taxpayer to be liable for significantly higher taxes.
Published on November 30, 2012

Leasing Business Autos

Article ...certain advantages. They require a minimal investment and are convenient if the customer replaces the car every two or three years. With a lease, there is no hassle with selling or trading in the car. Instead, the lease customer simply drops it off at the end of
Published on January 28, 2011

CPAs at Risk as Government Continues to Attack Abusive Tax Shelters

Article Through regulations and other forms of guidance issued since 1999, the IRS has clearly put tax practitioners on notice that it considers tax shelter transactions that generate noneconomic tax losses as not allowable for federal income tax purposes.
Published on May 10, 2010

Favorable Guidance Issued on Deferral of Gift Card Sales and Gift Cards Issued for Returned Goods

Article The IRS issued two taxpayer-favorable revenue procedures addressing the treatment of payments received for gift cards.
Published on July 20, 2011

Prop. Regs. on Sales-Based Royalties and Vendor Allowances

Article The IRS issued much-anticipated proposed regulations on the capitalization and allocation of sales-based royalties and on adjustments to the cost of merchandise inventory for sales-based vendor allowances.
Published on June 16, 2011

IRS Issues Guidance on Treatment of Gift Cards

Article This item provides background information on the tax and accounting treatment of gift card income and discusses two revenue procedures that address these issues.
Published on October 04, 2011

Growing Opportunities The Agricultural Chemical Security Credit

Article Taxpayers that deal with fertilizers and pesticides should consider their own facts and circumstances to determine how the agricultural chemical security credit might apply.
Published on January 28, 2011

Definition of Supplies Clarified for Purpose of R&D Credit

Article Taxpayers that use supplies in their research and development (R&D) efforts should reevaluate the costs they include in their R&D credit computations in light of a recent Tax Court decision (TG Missouri Corp.).
Published on January 28, 2011

Tax Consequences of Transaction Costs

Article ...article discusses the tax consequences of transaction costs in four settings: in general, when acquiring or producing tangible assets, when acquiring or creating intangible assets, and when acquiring a business
Published on October 04, 2011

Tax Implications of Transactions Involving Contingent Consideration

Article This article examines the tax and financial reporting consequences of companies using contingent consideration in payments for property and in payments to employees as compensation for services.
Published on August 01, 2010

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