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    Retiree Tax Planning for Eligible Retirement Plans of Tax-Exempt Entities

    Article Most types of tax-exempt entities may establish unfunded eligible deferred compensation plans under Sec. 457, sometimes called “top-hat” plans because they are designed for members of management and highly...
    Published on August 24, 2012

    Tax Treatment When Employees Surrender Paid Time Off to Benefit Others

    Article There are various types of PTO donation and leave-sharing programs, not all of which are disaster-related. The tax treatment to the donating employee differs based on the type of program
    Published on January 31, 2013

    Using a Limited Liability Partnership as the Entity of Choice

    Article A new type of entity that has appeared in the United States in recent years is the limited liability partnership (LLP) or registered limited liability partnership (RLLP). This entity is similar in...
    Published on January 28, 2011

    Teaching Tax Through the Socratic Method

    Article This column explores a type of active learning pedagogy that university and continuing education instructors should consider using in order to help students attain more permanent and meaningful learning
    Published on July 22, 2010

    A Different Type of Loan Fraud

    Newsletter What it is and how it is gaining ground.
    Published on December 29, 2009

    Estimating the Basis of Stock Acquired in a Type B Reorg.

    Article This item discusses issues addressed by Rev. Proc. 2011-35, which answers many questions and concerns regarding type B reorganizations
    Published on January 13, 2012

    Tax Treaty Net Basis Elections

    Article Tax treaties may offer special elections that recharacterize certain types of FDAP income that would otherwise be subject to withholding tax as effectively connected and thus taxable on a net basis at U.S. graduated rates
    Published on January 28, 2011

    U.S. Withholding Tax Requirements on Payments to Nonresidents and Foreign Entities

    Article This item provides an overview of the types of income subject to U.S. withholding tax and related U.S. information reporting requirements
    Published on April 01, 2013

    Prop. Regs. Expand Options for Private Foundations in Grant-Making Process

    Article The IRS proposed expanding the types of tax professionals on which private foundations may rely when making good-faith determinations as to the public charity status of foreign grantees
    Published on December 31, 2012

    Pretransaction Restructuring Using an F Reorg.

    Article This item explains how, within the context of a subchapter S corporation target, a Sec. 368(a)(1)(F) reorganization private letter ruling may present a structure that allows the parties to a reorganization to have their cake and eat it, too.
    Published on January 28, 2011

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