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    Edges of Acceptable Tax Planning

    Article The 11th Circuit affirmed the application of section 1031(f)(4) to a like-kind exchange that was structured by a corporation to avoid the purposes of the related party rule of section 1031(f). Ocmulgee Fields, Inc. v. CIR, No. 967-07 (11th Cir. 8/13/2010), aff'g, 132 T.C. No. 6 (2009). After an earlier similar ruling
    Published on January 28, 2011

    Tax Planning Opportunities With BAPTs

    Article A new tax planning idea that the authors of this item call a Business Asset Protection Trust (BAPT) creates a variety of income tax planning opportunities touching on international transfer pricing, S corporation...
    Published on July 31, 2014

    Tax Planning Opportunities With BAPTs

    Article A new tax planning idea that the authors of this item call a Business Asset Protection Trust (BAPT) creates a variety of income tax planning opportunities touching on international transfer pricing, S corporation...
    Published on July 31, 2014

    Edges of Acceptable Tax Planning

    Article The 11th Circuit affirmed the application of section 1031(f)(4) to a like-kind exchange that was structured by a corporation to avoid the purposes of the related party rule of section 1031(f). Ocmulgee Fields, Inc. v. CIR, No. 967-07 (11th Cir. 8/13/2010), aff'g, 132 T.C. No. 6 (2009). After an earlier similar ruling
    Published on January 28, 2011

    Tax Planning Opportunities for Funding an IRA

    Article This article explores various funding choices for IRAs and provides an approach or model by which the tax adviser can optimize the funding choice, given the taxpayer’s tax-related goals
    Published on August 24, 2012

    Tax Planning Opportunities for Funding an IRA

    Article This article explores various funding choices for IRAs and provides an approach or model by which the tax adviser can optimize the funding choice, given the taxpayer’s tax-related goals
    Published on August 24, 2012

    Nexus Update

    Article With the expansion of Internet use in businesses, it is now extremely uncommon for a state to incur an income tax liability in only one state. With the increase of service industries, state boundaries are blurring in the pursuit of business opportunities. With state budgets in precarious positions, legislators are...
    Published on January 28, 2011

    Nexus Update

    Article With the expansion of Internet use in businesses, it is now extremely uncommon for a state to incur an income tax liability in only one state. With the increase of service industries, state boundaries are blurring in the pursuit of business opportunities. With state budgets in precarious positions, legislators are...
    Published on January 28, 2011

    Unexpected Pitfalls in Using LLCs

    Article ...advent of the limited liability company (LLC) has in some ways simplified numerous transactions, both domestically and abroad. The LLC can combine liability protection to all owners, with passthrough tax treatment (if passthrough tax treatment is what the owner wants), even if the LLC does not qualify as an
    Published on January 28, 2011

    Unexpected Pitfalls in Using LLCs

    Article ...advent of the limited liability company (LLC) has in some ways simplified numerous transactions, both domestically and abroad. The LLC can combine liability protection to all owners, with passthrough tax treatment (if passthrough tax treatment is what the owner wants), even if the LLC does not qualify as an
    Published on January 28, 2011

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