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    Defending R&D Credits

    Article This article highlights and analyzes some recent decisions concerning the research and development (R&D) tax credit and IRS administrative practices when auditing R&D credit claims, most notably the Union Carbide decision in the Tax Court
    Published on May 01, 2010

    Are You Properly Paying the Ozone-Depleting Chemicals Excise Tax

    Article In recent years, IRS excise tax examinations have focused on taxpayers that import articles potentially subject to the excise tax imposed on certain ozone-depleting chemicals (ODCs) under Sec. 4681
    Published on June 01, 2010

    Potential Implication of Recent Sec. 469 Court Decisions for Self-Employment Tax Rules

    Article For purposes of self-employment taxes, many members of LLCs have treated themselves as limited partners and have therefore reported that their distributive share of income was not subject to self-employment tax under Sec...
    Published on July 01, 2010

    Reporting Uncertain Tax Positions

    Article This item explores the differences between financial statement reporting and federal income tax return disclosure in preparing for disclosure of uncertain tax positions on the Schedule UTP
    Published on April 01, 2011

    Foreign Disregarded Entities May Face U.S. FICA Tax Issue

    Article This item shows how restructuring international businesses to operate through entities disregarded for U.S. federal income tax purposes may also affect the employment tax treatment of the organization’s individual employees
    Published on June 01, 2011

    Reorganizations and Tax Attribute Survival

    Article Whether tax attributes will survive corporate tax reorganizations often becomes a critical consideration in assessing the ramifications of a proposed transaction. This item discusses issues surrounding these reorganizations and emphasizes the...
    Published on December 01, 2010

    IRS Increases Focus on Tax Hedge Identification Rules

    Article The IRS recently signaled its increasing interest in the tax treatment of hedging transactions, particularly with regard to proper taxpayer identification
    Published on May 01, 2011

    Health Care Reform Adds New Taxes

    Article The Patient Protection and Affordable Care Act (the Patient Protection Act) and the Health Care and Education Reconciliation Act of 2010 (the Reconciliation Act) add a number of new taxes and make various other revenue-increasing changes to the Code in order to help finance health care reform
    Published on May 01, 2010

    Prop. Regs. Would Eliminate Paper Coupons for Federal Tax Deposits

    Article The IRS has issued proposed regulations that, effective in 2011, would eliminate the option of making federal tax deposits by paper coupon. Going forward, taxpayers must submit all federal tax deposits using the Electronic Federal Tax Payment System (EFTPS
    Published on January 01, 2011

    Tax Return Preparers Win Partial Victory in Fraudulent Credit Scheme Case

    Article A district court found that two tax return preparers who had participated in a fraudulent scheme involving credits for fuel from nonconventional sources did not know the scheme was fraudulent and dismissed the IRS’s requests...
    Published on December 01, 2011

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