TaxClinic

Practical Advice
on Current Issues

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

IN THIS DEPARTMENT

Accounting Methods & Periods

TAM links scope of LIFO election to LIFO pooling method

Consolidated Returns

Are the new loss duplication regulations out of date?

Corporations & Shareholders

Basis of debt obligations in certain transactions

Regulations offer flexibility in meeting COI requirement

Employee Benefits & Pensions

Funding arrangements under Sec. 409A

New IRS focus on fringe benefits

Exempt Organizations

Election-year focus on lobbying and political activities of public charities

Foreign Income & Taxpayers

New U.S. reporting requirements for foreign multinationals

Gains & Losses

Caveat emptor: stock acquisition CERT limit on NOL use

TAM addresses like-kind exchange of intangibles

Partners & Partnerships

Partner loans: traps for the unwary

Procedure & Administration

Determining number of owners for entity classification elections

IRS treatment of protective refund claims

Limits on refunds for NOL carrybacks

Pattern evidence in tax shelter litigation

If you would like additional information about these items, contact Ms. Smith at (202) 414-1048 or annette.smith@us.pwc.com.

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