The Tax Adviser March 2012 


    The S Corporation Built-In Gains Tax: Commonly Encountered Issues
    Kevin D. Anderson

    When Is Form 8283 Required to Be Filed?
    Michael V. Schaefer, Elizabeth C. Connor, Douglas M. Laufer, and Gregory Clifton

    Individual Taxation Developments
    Ellen Cook, Karl L. Fava, Edward A. Gershman, Janet C. Hagy, Jonathan Horn, Daniel T. Moore, Annette Nellen, Dennis Newman, Teri E. Newman, Kenneth L. Rubin, and Amy M. Vega

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    The S Corporation Built-In Gains Tax Commonly Encountered Issues

    Article This article examines five issues corporations commonly encounter in complying with the built-in gains tax.
    Published on March 01, 2012

    Impact of Millennials on CPA Firms

    Article As members of the Millennial generation continue to enter the workforce, CPA firms will increasingly need to focus on how to successfully attract, motivate, develop, and retain these individuals.
    Published on March 01, 2012

    ODC Tax Liability and Audit Information Cannot Be Disclosed

    Article The Federal Circuit held that audit tests and related information of third-party taxpayers pertaining to the assessment of the ozone-depleting chemicals excise tax was return information not subject to disclosure under Sec. 6103(a).
    Published on March 01, 2012

    Banks Are Lenders to Partnership, Not Partners

    Article The Second Circuit held that two banks were lenders to a partnership, not partners in the partnership under Sec. 704(e)(1).
    Published on March 01, 2012

    Sec. 402(b) and Foreign Pension Plans

    Article Cross-border transfers of employees affect their pension plans and other deferred compensation arrangements. In some of these instances, some or all of the amounts may be subject to U.S. taxation.
    Published on March 01, 2012

    U.S. Sandwich Structures in the International Inbound Context

    Article When a foreign multinational operates in the United States through a U.S. group that has underlying foreign operations—a “U.S. sandwich structure”—repatriating the U.S. group’s foreign earnings often results in tax inefficiencies.
    Published on March 01, 2012

    Family Investment Partnerships All the Perks

    Article Family investment partnerships are frequently used to manage and control multigenerational family wealth and may result in significant economic and tax benefits.
    Published on March 01, 2012

    Application of the Tax Basis and At-Risk Loss Limitations to Partners

    Article Individual partners who have been allocated a distributive share of loss must satisfy three separate loss limitations before the loss can be used.
    Published on March 01, 2012

    When Is Form 8283 Required to Be Filed

    Article The IRS should revise the instructions for Form 8283 to more clearly explain when it is required to be filed, given that the instructions state that failure to file the form can cause the deduction to be disallowed in its entirety.
    Published on March 01, 2012

    IRS Chief Counsel Continue Applying Valuation Misstatement Penalties

    Article The IRS recently addressed the application of the valuation misstatement penalties contained in Secs. 6662(b)(3) and 6662(h).
    Published on March 01, 2012

    Individual Taxation Developments

    Article This article covers recent developments affecting individual taxation. The items are arranged in Code section order
    Published on March 01, 2012

    Assisting the Newly Widow[er]ed

    Article This article discusses ways to aid clients who have suffered the loss of a spouse or other close loved one.
    Published on March 01, 2012

    Preserving Tax Losses by Avoiding the Wash-Sale Rules

    Article A taxpayer cannot deduct the loss realized on the sale of stock or securities (including shares in a mutual fund) if the taxpayer purchases substantially identical stock or securities within the period beginning 30 days before and ending 30 days after the sale.
    Published on March 01, 2012

    Third Offshore Voluntary Disclosure Program Launched

    Article The IRS announced it was starting a third offshore voluntary disclosure initiative (OVDI) designed to help people with unreported offshore accounts get current with their taxes in the United States.
    Published on March 01, 2012

    New Guidance on W-2 Reporting of Health Plan Costs

    Article The IRS released new guidance on the requirement that employers provide information to employees on the cost of employer-provided group health plan coverage.
    Published on March 01, 2012

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