The Tax Adviser July 2013 

    Photo by iStockphoto/Thinkstock Articles

    Using the First-Time Penalty Abatement Waiver
    Jim Buttonow

    Advising Clients Regarding Erroneous Tax Return Positions (Part II)
    Michael E. Baillif

    Targeted Partnership Allocations (Part II)
    Noel P. Brock



    Consolidated Returns

    Opportunity to Eliminate Certain Intercompany Gain

    Corporations & Shareholders

    Entities With Less Than $50 Million in Assets Get New Schedule M-3 Filing Rules

    Sec. 336(e) Election Regulations Are Issued

    Failing Subchapter C Requirements to Avoid Nonrecognition Treatment

    Whether Incentives That Require Companies to Provide Jobs Should Be Treated as Nonshareholder Capital Contributions

    Credits Against Tax

    ATRA Allows Taxpayers to Continue to Accelerate Certain AMT Credits

    Employee Benefits & Pensions

    Proposed Rules Address Minimum Value of Health Coverage for Premium Tax Credits

    Employment Taxes

    Totalization Agreements: Taking Exception to Social Security

    Options for Compliance With Worker Classification Rules

    Expenses & Deductions

    Nine Factors That Determine Whether an Activity Is a Hobby

    Foreign Income & Taxpayers

    Defining “Attributable to” Under Sec. 897(g)

    Foreign Branch Incorporation: Interaction of OFL, Branch Loss Recapture Rules

    Interplay of Withholding Obligations on Partnership’s Disposition of U.S. Real Property

    Gross Income

    Loan Guarantees Were Prohibited Transactions That Disqualified IRAs


    IRS Issues HSA Inflation Adjustments for 2014

    Innocent-Spouse Defense Against Assessments on a Joint Return

    Partners & Partnerships

    Application of Sec. 704(c) to Divisions

    Final Regulations for Noncompensatory Partnership Options

    Targeted Partnership Allocations: Part II

    Practice & Procedures

    Using the First-Time Penalty Abatement Waiver

    Advising Clients Regarding Erroneous Tax Return Positions: Part II

    CPAs and Comfort Letters: The New Chocolate

    Procedure & Administration

    IRS Will Get Search Warrants When Seeking Taxpayer Emails

    Final Regs. Permanently Extend Period to Receive Disclosure Authorization

    Final Regs. Require EIN Holders to Update Information With IRS

    Questions on EINs in F Reorganizations Involving Disregarded Entities

    Unresolved Issues Regarding Sec. 6603 Deposits

    The Collection Appeal Procedures and Collection Due Process Programs

    Schedule UTP: Update on IRS Findings

    A Closer Look at the IRS’s Targeting of Tea Party and Other Groups for Review

    S Corporations

    LIFO Inventory Considerations When Making a C-to-S Conversion

    Tax Accounting

    Timing of Revenue Recognition for Retainages

    Understanding the Principles of DASTM Accounting

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