TaxClinic
Practical Advice
on Current Issues
.
Editor:
Robert
Zarzar, CPA
Partner
Washington National Tax Services
PricewaterhouseCoopers
Washington, DC
If you would
like additional information about these articles, contact
Mr. Zarzar
at (202) 414-1705.
Corporations
& Shareholders
Sec.
301(e)—some unusual consequences
Unwanted
assets in a stock sale
Credits Against
Tax
AIRC
opportunities and new allocation regs.
Employee
Benefits & Pensions
Compensating
employees with nonemployer stock options
Consequences
of failing to provide suspension-of-benefits notice
Timing of
incentive compensation deductions
Exempt
Organizations
Sponsorship
prop. regs. may increase UBIT liability
Expenses
Government
clarifies position on investigatory costs
IRS should
allow expensing of ERP implementation costs
Long-term
contract costs ruled capital expenditures
Removal
costs held deductible
Foreign Income
& Taxpayers
AICPA
comments on "check-the-box" prop. regs.
Effect of
NOL carryovers on FTC
Foreign
taxes may reduce stock option benefits
Redemption
distributions of PTE
Sec.
904—base difference vs. timing difference for
foreign taxes
Gains &
Losses
BIGs and
items of income under Sec. 382
Procedure &
Administration
Applicability
of Sec. 6662 accuracy-related penalties to refund
claims
Current
issues in information reporting
Unanticipated
tax consequences under the conversion regs.
S Corporations
Application
of step-transaction doctrine to QSub elections
Unless otherwise indicated,
contributors are members of or associated with KPMG LLP.
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