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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 January 28, 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 October 04, 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

    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 November 30, 2011

    Planning for the New Medicare Taxes

    Article The recently passed 2010 health care reform legislation added two additional Medicare taxes intended to help pay for the new legislation. This item looks at the details of both the 3.8% investment income tax and the 0.9% hospital insurance tax...
    Published on December 01, 2010

    Global Tax Treatment of Equity Awards

    Article Careful consideration is needed before a company begins to issue long-term incentives in foreign tax jurisdictions
    Published on January 28, 2011

    Controlling Interest Provisions in State and Local Real Estate Transfer Taxes

    Article A common way for a taxpayer to transfer real estate to a new owner without paying a real property transfer tax has been to transfer an ownership interest in an entity that holds title to the property. However, a number of jurisdictions now require taxpayers who engage in these types...
    Published on January 13, 2012

    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 January 28, 2011

    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 January 28, 2011

    Tax Law Changes Delay Start of Filing Season for Some Taxpayers

    Article The IRS has warned taxpayers that it will not be accepting certain 2010 individual tax returns until mid- or late February, due to tax law changes enacted by Congress late in 2010. Taxpayers affected include all those who itemize deductions on Schedule A, as...
    Published on February 01, 2011

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