The Tax Adviser July 2010 

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    Sec. 465 Traps for the Unsuspecting S Corporation Shareholder

    Article Without proper planning, the at-risk rules set out in Sec. 465 can limit the amount of deductible S corporation losses.
    Published on July 01, 2010

    Tax Benefits for Education

    Article An array of tax benefits are available to taxpayers, including income exclusions for educational assistance, scholarships, and distributions from qualified tuition plans and educational IRAs, as well as credits for tuition and certain education-related expenses and a deduction for tuition payments.
    Published on July 01, 2010

    Back to the Basics Common Gift Tax Return Mistakes

    Article This article addresses various issues that may arise in the preparation of federal gift tax returns, with a focus on gift tax returns that will be filed to report gifts made during 2009 or 2010.
    Published on July 01, 2010

    State and Federal NOL Rules Differ in Key Respects

    Article State net operating loss (NOL) rules generally differ from federal NOL rules, and state NOL rules often differ from one another. This lack of consistency can lead to confusion about a taxpayer’s ability to utilize NOLs.
    Published on July 01, 2010

    Refund Allowed After Carryback Recapture Held Entitled to Overpayment Interest

    Article The Court of Federal Claims last year awarded the Coca-Cola Company overpayment interest on an overpayment of tax that previously had been (1) allowed as a tentative refund and then (2) recaptured and held for six years by the IRS.
    Published on July 01, 2010

    Lack of Limitation Period on Certain Adjustments Affirmed in Recent Decision

    Article A recent case illustrates that courts may sustain the government when it makes adjustments to closed years only to determine whether an overpayment of tax exists, and not to recover additional taxes beyond the limitation period on assessment.
    Published on July 01, 2010

    Conversion of Corporation to LLC Raises EIN Retention Questions

    Article A company that is considering converting a corporate subsidiary to an LLC should determine whether the EIN will be reassigned to the LLC before filing any state conversion document.
    Published on July 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. 1402(a)(13). If recent Sec. 469 court cases were to be applied beyond Sec. 469, this self-employment tax
    Published on July 01, 2010

    Special Reporting Requirements for U.S. Domestic Use of U.K. Dual Consolidated Loss

    Article A U.S. corporation that incurs a dual consolidated loss (DCL) generally is prohibited from using the loss to reduce U.S. taxable income. If the DCL is from a loss incurred by a company organized under the laws of the United Kingdom, the U.S. company must comply with additional reporting requirements
    Published on July 01, 2010

    Application of Sec. 1297(d) Overlap Rule to PFIC Shares Held by a U.S. Partnership

    Article Letter Ruling 200943004 provides helpful insight into IRS thinking with respect to the application of the PFIC/CFC overlap rule in the partnership context.
    Published on July 01, 2010

    Application of Entity Classification Elections to Shelf Company Acquisitions

    Article When electing the entity classification of a newly acquired foreign shelf company, the taxpayer must consider several procedural issues.
    Published on July 01, 2010

    Allocations of Sec. 179D Deductions by Government Building Owners

    Article To meet new emissions reduction targets, federal agencies are likely to continue including more requirements in contracting protocols throughout the government’s supply chain. While these energy-efficiency targets create opportunities for designers under Sec. 179D, they can also create challenges for suppliers and others contracting with the government when determining who
    Published on July 01, 2010

    IRS Taking Firm Approach to Ozone-Depleting Chemical Excise Tax Compliance

    Article The IRS has recently reinvigorated its examination of the ozone-depleting chemicals tax, adopted a strict interpretation of the regulations, and instituted a laboratory testing program to detect ODCs in printed circuit boards.
    Published on July 01, 2010

    Tax Implications of the Five-Year NOL Carryback

    Article An extended carryback period of up to 5 years is available for NOLs generated in 2008 or 2009. The author reviews some of the practical issues that should be considered when deciding whether to take advantage of the extended NOL carryback period.
    Published on July 01, 2010

    Substantially Equal Payment Exception

    Article One of the most useful exceptions to the early distribution tax (particularly for IRA distributions before the taxpayer is age 59½) is the exception for substantially equal payments.
    Published on July 01, 2010

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