TaxClinic
Practical
Advice
on Current Issues
.
David J. Kautter
Partner
Ernst & Young LLP
Washington, DC
Consolidated
Returns
IRS issues proposed
anti-loss-duplication consolidated regs.
Subsidiary's nonconforming
inventory method will not violate group's conformity
Corporations &
Shareholders
Prop. regs. bar use of basis
shifting to create artificial losses
Employee
Benefits & Pensions
DOL issues Enron-driven
“blackout” rules
Estates,
Trusts & Gifts
Trust's payments to S
corporation for personal services not act of
self-dealing
Excise
Taxes
Ruling revoked on
communications tax exemption
Exempt
Organizations
Charging related private
foundation for services was not act of self-dealing
Expenses
Rev. Rul. disallows LILO
transaction deductions
Gains
& Losses
Bank subsidiary's LKE program
qualifies under Sec. 1031
Put and qualified covered call
option on same equity results in straddle treatment
Transfer of stock warrants to
charity was not anticipatory assignment of income
Individuals
IRS allows one-time RMD-method
change
Procedure
& Administration
IRS eases late
“check-the-box” election procedures
Special Industries
Service identifies
“listed transaction” insurance arrangement
Unless
otherwise indicated, contributors’ firms are members
of or associated with Ernst & Young LLP.
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