The Tax Adviser 2009 



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    The Tax Adviser August 2009

    Published on March 11, 2013

    Current Developments in Employee Benefits and Pensions (Part I) - 2009

    Article This two-part article provides an overview of current developments in employee benefits, focusing on new guidance regarding executive compensation and health and welfare benefits.
    Published on January 22, 2013

    Current Corporate Income Tax Developments (Part II) - 2009

    Article During 2008, numerous state statutes were added, deleted, or modified; court cases were decided; regulations were proposed, issued, and modified; and bulletins and rulings were issued, released, and withdrawn. This article covers some of the more important developments in apportionment, unitary groups/filing methods, administration, flowthrough entities, and other significant corporate
    Published on January 22, 2013

    Two Recent Revenue Rulings Clarify Tax Treatment of Life Settlements

    Article The IRS issued two revenue rulings discussing the taxation of life settlement transactions. Rev. Rul. 2009- 13 clarifies the tax implications of the surrender or sale of a life insurance policy by the original policyholder, while Rev. Rul. 2009-14 discusses the tax ramifications of certain transactions to an investor who
    Published on July 13, 2012

    Restructuring Partnership Debt May Create Unexpected Results

    Article A partnership or an LLC taxed as a partnership contemplating a debt restructuring should carefully consider the tax effects of Sec. 108.
    Published on July 13, 2012

    Deducting Ponzi Scheme Losses Practical Issues

    Article In March 2009, the IRS issued Rev. Rul. 2009-9 and Rev. Proc. 2009-20, which provided guidance on the tax treatment of theft losses from Ponzi-type schemes.
    Published on July 13, 2012

    Maneuvering Through the Proposed Rules for Post-Transaction Accounting Methods

    Article Proposed regulations address the process for determining and changing methods of accounting following certain corporate reorganizations and liquidations.
    Published on January 28, 2011

    Method Changes Within the Nonaccrual Experience Method

    Article A nonaccrual experience method of accounting, as described in Sec. 448(d) (5), allows certain service providers to except from accrual the portion of revenue they have determined will not be collected, based on their own experience and through the use of formulas allowed under this section and the regulations.
    Published on January 28, 2011

    AMT Consequences of an Ownership Change

    Article While most tax planning routinely contemplates the impact of the Sec. 382 limitation on the use of a corporation’s net unrealized built-in losses (NUBILs) following an ownership change, the corresponding impact of Sec. 56(g)(4)(G) for adjusted current earnings (ACE) is often overlooked and may have a significantly different effect than
    Published on January 28, 2011

    Drop Shipments and Flash Title Establishing Sales Tax Nexus in Complex Commercial Transactions

    Article This column discusses substantial and attributional nexus and examines how nexus is asserted for sales and use tax purposes in drop shipment and flash title transactions.
    Published on January 28, 2011

    Deferring Shareholder Gain by Distributing Installment Notes

    Article When a C corporation sells some or all of its assets during the process of liquidation and takes back one or more installment notes as payment, it must recognize, in the year of liquidation, all unrecognized gains on installment receivables distributed to the shareholders (Secs. 336 and 453B(a)).
    Published on January 28, 2011

    Debt Restructurings in Todays Private Equity Environment

    Article Deals that are taking place today bring with them many technical tax considerations that were seen much less frequently during robust economic times.
    Published on January 28, 2011

    Creative Ways of Achieving Grantor Trust Status

    Article Trusts that may not appear to qualify as S corporation shareholders could actually be grantor trusts eligible to own S corporation stock.
    Published on January 28, 2011

    ETAAC Makes Recommendations to Congress, Including Mandatory E-Filing

    Article The Electronic Tax Administration Advisory Committee made 10 recommendations to help the IRS achieve its goal that 80% of all tax and information returns be e-filed.
    Published on January 28, 2011

    Client Data Security for the Tax Practitioner

    Article This column takes a brief look at some practices CPAs should consider when handling data security.
    Published on January 28, 2011

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