Table of Contents - April 2009
Note: In accordance with IRS Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers before the Internal Revenue Service, the information on this website is not intended or written to be used as, and cannot be used as or considered to be a "covered opinion" or other written tax advice, and should not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute or other purposes.
Bullets indicate items in the Tax Clinic department.
Accounting Methods & Periods
• When Is a Rebate Liability Fixed and Eligible for the Recurring-Item Exception?
Corporations & Shareholders
Proposed Regs. Provide Model for Stock Basis Recovery and Identification
• IRS Issues Helpful Regs. on the Interplay of Active Trade and Hot Stock
• New Continuity-of-Interest Regs. Expand Definition of Qualifying Stock Recipients in a Reorg.
• Personal Goodwill: Alive and Well?
Employee Benefits & Pensions
• Qualified Plans: Partial Plan Terminations
Deduction for ESOP Distributions Disallowed
Exempt Organizations
• Transfers Between Controlled Entities Can Provide Surprises Under Sec. 512(b)(13)
Internal Controls and Exempt Organization Executive Compensation Arrangements
IRS Releases Redesigned Form 990
Foreign Income & Taxpayers
• New Subpart F Regs. Address Manufacturing Exception and Branch Rules
• Transfer Pricing: The New Temporary Cost-Sharing Regs.
Gains & Losses
• Discharge of Indebtedness: Conversion vs. Contribution of Indebtedness
Like-Kind Exchanges: Deferral Is Not Always the Best Option
Legislation
Numerous Tax Provisions in Stimulus Act
Partners & Partnerships
• Target or Waterfall: Partnership Allocations
Personal Financial Planning
Ponzi Schemes: The Implications for Defrauded Investors
Practice & Procedures
Accountant Workpaper Privilege Upheld by First Circuit
The National CPA-IRS Tax Issues Meeting
Procedure & Administration
IRS Expands Alternative Dispute Resolution Opportunities
Return Preparer’s Advice Does Not Prevent Accuracy-Related Penalty
Tax Court Not Limited to Administrative Record in Innocent Spouse Cases
S Corporations
Distressed S Corporations: Tax Issues Involved in Restructuring
State & Local Taxes
Current Corporate Income Tax Developments (Part II)
Refundable State and Local Tax Credits
