TaxClinic

Practical Advice
on Current Issues

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Editor:
David Madden, J.D., LL.M.
Principal
Washington National Tax Service
KPMG LLP
Washington, DC

Accounting Methods & Periods

IRS guidance on the nonaccrual experience method of accounting

Proposed Rev. Proc. on advance payments clears up ambiguities

Bankruptcy & Insolvency

Tax Court can interpret bankruptcy discharge order

Corporations & Shareholders

Letter rulings flirt with limits of liquidation-reincorporation doctrine

Ruling sheds light on preferred-stock definition

Variations on a D reorganization theme

Expenses

Tax implications on the financial accounting treatment of cooperative advertising reimbursements

Foreign Income & Taxpayers

Applying the indirect ownership rules to PFICs

Congresss end game of catching wealthy expatriators

PFIC/CFC overlap: not out of the woods yet

Gross Income

New guidance for vendors income recognition

Ninth Circuit reverses Tax Court on timing of DOI income 

Partners & Partnerships

CCAs address partnership transactions

Prop. regs. issued on noncompensatory partnership options

If you would like additional information about these items, contact Mr. Madden at (202) 533-3056 or dmadden@kpmg.com.

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