Retiree Tax Planning for Eligible Retirement Plans of Tax-Exempt Entities
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 January 01, 2012
Using a Limited Liability Partnership as the Entity of Choice
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 June 01, 2009
Teaching Tax Through the Socratic Method
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 November 01, 2008
Tax Treatment When Employees Surrender Paid Time Off to Benefit Others
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 February 01, 2013
Estimating the Basis of Stock Acquired in a Type B Reorg.
This item discusses issues addressed by Rev. Proc. 2011-35, which answers many questions and concerns regarding type B reorganizations
Published on September 01, 2011
Another Tax Enforcement Trap The Qui Tam Action in New York v. Sprint Nextel Corp.
New York is using a relatively new type of tax enforcement mechanism against Sprint Nextel Corp.: a qui tam action
Published on October 01, 2014
Tax Treaty Net Basis Elections
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 May 01, 2009
U.S. Withholding Tax Requirements on Payments to Nonresidents and Foreign Entities
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
Retiree Tax Planning With Qualified Longevity Annuity Contracts
The IRS recently issued regulations authorizing a new type of annuity contract for certain tax-favored retirement plans and IRAs: Qualified longevity annuity contracts
Published on November 01, 2014
Prop. Regs. Expand Options for Private Foundations in Grant-Making Process
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 January 01, 2013