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Table of Contents
August 2007

Note: In accordance with IRS Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers before the Internal Revenue Service, the information on this website is not intended or written to be used as, and cannot be used as or considered to be a "covered opinion" or other written tax advice, and should not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute or other purposes.
Asterisks indicate items in the Tax Clinic department.
 

Accounting Methods & Periods

    Prepaid Services Must Be Fully Completed to Use 3½-Month Rule
 
Employee Benefits & Pensions
  * Executive Stock Options under Senate Review
 
Estates, Trusts & Gifts
  * Seven Suggestions for IRS Estate/Gift Tax Audits
 
Exempt Organizations
  * IRS Bite Beginning to Mirror Its Bark
 
Expenses
  * New Ruling Expands Definition of “North American Area” for Attendance at Foreign Conventions
    Rules Governing Lodging Away from Home Will Be Liberalized
 
Foreign Income & Taxpayers
* New Regs. for Use of Foreign Losses Included in U.S. Tax Filings: Dual Consolidated Losses
* Repatriated Earnings under Sec. 965: Using the Safe-Harbor Test in 2007 to Ease Compliance Reporting and Protect Tax Benefits
Individuals’ Use of Offshore Holding Companies (Part I) by Paul M. Schmidt and Todd C. Lady
 
Individuals
  * Divorce and Gain Exclusion
 
Legislation
    New Law Contains Small Business Tax Provisions
 
LLCs & LLPs
  * Tax Court Says Taxpayer Not at Risk for DRA
    The Rising Popularity of SMLLCs in Tax and Business Planning by Ryan H. Pace
 
Practice & Procedures
    Patenting Tax Ideas by Justin P. Ransome and Eileen Sherr
    The Tax Gap
 
Procedure & Administration
    Check-the-Box Regs. Upheld
    Preparer Penalties
 
Real Estate
  * Ninth Circuit Affirms Self-Rental Rule
 
S Corporations
  * Open Account Debt for S Shareholders
    Claiming Passive Activity Credits
 
Special Industries
  * Transfers to Investment Companies: Pitfalls of Secs. 351 and 721
 
State & Local Taxes
  * Change in Ohio Residency Rules
 
Tax Education
    VITA, the MTC and the Modern Accounting Curriculum (Part I)
 

Special Feature

  * "Best Article" Award
 
Reader Survey

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