TaxClinic
Practical Advice
on Current Issues
.
Editor:
David Madden, J.D., LL.M.
Principal
Washington National Tax Service
KPMG LLP
New York, NY
Accounting Methods
& Periods
IRS eases
rules for accounting-method-changes
Significant
new guidance for changing an accounting method
The
"simplified" IPIC method
Consolidated Returns
Rite Aid precipitates
issuance of prop. and temp. regs.
Corporations &
Shareholders
Treatment of
intercompany debt in a reorganization
Employee Benefits
& Pensions
TAM blesses
plan "inoculation" language
Expenses
Deductibility
of exit and entrance fees paid to the FDIC
Proposed
guidance on capitalization
Sec. 162
demutualization payments deductible, but not until
paid
Foreign Income &
Taxpayers
Cross-border
guarantee fees subject to U.S. withholding tax
PFICs:
applying the subsidiary look-through rules to
intercompany transactions
Phantom
foreign currency gain on foreign property
Temp. regs.
expand relief for foreign persons failing to file
U.S. returns
U.S.
companies' sales to EU consumers subject to VAT on
digital downloads
Gains & Losses
Tax Court
expands Sec. 1033's scope
Gross Income
Going for the
gold: Sec. 280A and Olympic rentals
Interest Income
& Expense
Interest
deductions for bankrupt corporations
Partners &
Partnerships
Rev. Proc.
2002-22: co-ownership of property or partnership
interest?
Unless otherwise indicated,
contributors are members of or associated with KPMG LLP.
If you would like additional
information about these articles, contact Mr. Madden at
(202) 533-3056 or dmadden@kpmg.com .
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