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TaxClinic

Practical Advice
on Current Issues

.


Editor:
Annette B. Smith, CPA
Partner
Washington National Tax Service
PricewaterhouseCoopers LLP
Washington, DC


Consolidated Returns

Intercompany transaction and loss disallowance relief provisions


Credits Against Tax

Continuing uncertainty on research credit definition of gross receipts


Exempt Organizations

Executive compensation reporting and taxation of automatic excess-benefit transactions

  

Expenses

Retention of the separate and distinct asset test in the final intangible asset regs.

  

Gains & Losses

Proposed notional principal contract regs. address contingent payments and character

Sec. 1271(a)a pitfall for unwary corporate creditors

  

LLCs & LLPs

Series LLC tax issues

  

Procedure & Administration

When must the IRS pay interest on refunds?

  

Special Industries

Using captives to manage risk

  

State & Local Taxes

Accrual of California franchise tax liabilities

  

If you would like additional information about these items, contact Ms. Smith at (202) 4141048 or annette.smith@us.pwc.com.

Unless otherwise indicated, contributors are members of or associated with PricewaterhouseCoopers LLP.


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2004 AICPA