Tax Return Due Diligence Basic Considerations
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This article examines the rules of due diligence and the importance of tax professionals understanding these rules and proactively adapting to them in a practical manner.
Published on April 27, 2011
Termination of an LLC
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This column reviews the determination of when an event triggers the termination of an LLC classified as a partnership
Published on October 19, 2010
Do We Really Have Privilege
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This item discusses the limits of the privilege for communications between a tax practitioner and client under Sec. 7525.
Published on October 05, 2010
IRS Auditing Through QuickBooks
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The IRS has provided QuickBooks accounting software training to its Small Business/Self-Employed (SB/SE) division examiners.
Published on October 05, 2010
National Taxpayer Advocate Warns of IRS Mission Expansion
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In the introduction to her recent report to Congress, IRS National Taxpayer Advocate (NTA) Nina Olson warns that recent expansion of the IRS mission is straining some of its core capabilities.
Published on October 05, 2010
IRS Issues Interim Report on the Colleges and Universities Compliance Project
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The IRS recently issued an interim report on the Colleges and Universities Compliance Project that was initiated by the Exempt Organizations (EO) function of the Tax Exempt and Government Entities (TE/GE) division.
Published on October 05, 2010
Significant Recent Developments in Estate Planning (Part II)
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This discusses the estate tax, generation-skipping transfers, trusts, changes made by the Economic Growth and Tax Relief Reconciliation Act of 2001, and the annual inflation adjustments for 2010 relevant to estate and gift tax.
Published on October 05, 2010
Accuracy-Related Penalty Applied Despite Reliance on Adviser
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The Tax Court held that a corporation was liable for an accuracy-related penalty for a substantial understatement of tax related to a joint venture transaction even though the corporation had received an opinion from a national accounting firm that the transaction was not taxable.
Published on October 05, 2010
Decedent Did Not Retain Possession and Enjoyment of Entire Property
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The Second Circuit held that the Tax Court clearly erred in finding that the terms of an implied agreement between a decedent and her son provided that the decedent would retain enjoyment of the entirety of a 49% share in a Manhattan brownstone that she had given to the son
Published on October 05, 2010
Rules Issued on Income Deferral of Canceled Debt
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The IRS issued temporary and proposed regulations relating to taxpayer elections to defer recognition of cancellation of debt income.
Published on October 05, 2010
Final Regs. Released for Payment Card and Third-Party Network Information Reporting
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The IRS has issued final regulations regarding the new information reporting requirement under Sec. 6050W for payment card and third-party network transactions.
Published on October 05, 2010
Congress Votes to Limit Use of Foreign Tax Credits
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P.L. 111-226 makes changes to how corporations can use the foreign tax credit and also terminates the advance refundability of the earned income credit (under Sec. 3507), effective for tax years beginning after December 31, 2010.
Published on October 05, 2010
IRS Changes Name, Expands Focus of LMSB Division
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The IRS announced that it is reorganizing and changing the name of its Large and Mid-Size Business division as part of its ongoing effort to focus more on international tax compliance. Starting October 1, 2010, the division will be known as the Large Business and International (LB&I) division.
Published on October 05, 2010
IRS Will Stop Providing Debt Indicators Exploring Ways for Taxpayers to Use Refunds to Pay Preparers
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The IRS announced that it will stop providing “debt indicators” to tax preparers and associated financial institutions.
Published on October 05, 2010
IRS Moves Forward with Preparer Registration Plan
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On August 19, the IRS issued proposed regulations that would put into place many of the parts of its plan to register and regulate tax return preparers. This item reviews those proposed regulations and their possible impact on tax professionals.
Published on October 05, 2010