Table of Contents - July 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.
Corporations & Shareholders
• Stock Basis Recovery in Outbound Sec. 304 Transfers
Credits Against Tax
Residential Energy-Efficient Property Credit Rules Issued
Employment Taxes
• Correcting Employment Tax Errors
Estates, Trusts & Gifts
Prop. Regs. on Graduated Retained Interests Under Sec. 2036
Exempt Organizations
• Sponsorships Offer Opportunities for Nonprofits, Corporations
Clergy Tax Rules Extend Beyond Churches
Expenses and Deductions
Foreign Income & Taxpayers
• Adopting or Changing a Foreign Corporation’s Accounting Method
• Initial IRS Guidance Addressing EU Cap-and-Trade Systems, Subpart F Rules
• Revised Form 1120-F: Practical Issues and Missed Opportunities
• U.S. Tax Effects of a Foreign Jurisdiction Audit
Expatriation and the New Mark-to-Market Rules
Report of Foreign Bank and Financial Accounts: Significant Revisions and Severe Penalties
Gains & Losses
Guidance on Sales and Purchases of Life Insurance Contracts
IRS Clarifies Guidance on Small Business NOL Carrybacks
• Effect of Debt Recharacterization on Worthless Securities Deductions
Deducting Losses for Defrauded Investors
IRS Issues Optional Safe-Harbor Treatment for Victims of Ponzi Schemes
Tax Shelter Transactions Disregarded
Gross Income
• Should a Company Elect to Defer Cancellation of Debt?
Personal Financial Planning
Estate Planning While We Sit, Watch, and Wait
Practice & Procedures
Consent to Extend the Statute of Limitation
Textron: A Still Uncertain Future for Tax Accrual Workpapers
Procedure & Administration
• Protecting Refunds of Certain Overpaid Deficiency Interest
The National Taxpayer Advocate’s Annual Report to Congress (Part I)
S Corporations
Revenue Ruling on S Elections for Partnerships Converting to Corporations
Tax Accounting
Taxpayer Not Allowed to Defer Income on Sale of Partnership Interest
