The Tax Adviser May 2012 


    Interpretations of SSTS No.1, Tax Return Positions
    John Gardner, Barbara Eide, Bruce May, and Diane May

    Reporting Dilemma: Personal Use of Rental Properties
    Janet C. Hagy

    FBAR: Handle With Care
    Randall Andreozzi and Arlene Hibschweiler


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    Benefiting From Unique Attributes of ESOPs

    Article An employee stock ownership plan (ESOP) is a stock bonus plan or a combination of a stock bonus plan and money purchase pension designed to invest primarily in stock of the employer.
    Published on May 01, 2012

    Sec. 6045B Reporting Requirements

    Article Sec. 6045B requires an issuer of a specified security to report certain information to the IRS and to its shareholders following an organizational action that affects the basis of a specified security.
    Published on May 01, 2012

    Intercompany Debt in a Deemed Asset Sale Election

    Article This item discusses IRS guidance illustrating the impact of extinguishment of intercompany debt immediately preceding a Sec. 338(h)(10) election.
    Published on May 01, 2012

    The Research Credit and Deduction for Passthrough Entities

    Article Passthrough entities may be overlooking the research tax credit because they are not aware that they are engaged in eligible activities, do not think their activities are qualified, or do not believe they can meet the various requirements.
    Published on May 01, 2012

    Trust Deductions Knight, Prop. Regs. Still Govern

    Article Preparers of fiduciary tax returns for tax years 2011 and 2012 will not be required to unbundle fiduciary fees, but they still must treat payments readily identifiable as subject to the 2% floor separately from a bundled fiduciary fee.
    Published on May 01, 2012

    LB&I Guidance on Benefits-and-Burdens-of-Ownership Analysis Under Sec. 199

    Article The IRS LB&I Division issued guidance to field examiners in determining whether a taxpayer conducting production activities under a contract manufacturing arrangement with an unrelated third party meets the benefits-and-burdens-of-ownership requirement outlined in the domestic production activities deduction rules under Sec. 199.
    Published on May 01, 2012

    Tangible Property Regulations

    Article The IRS recently released the long-awaited tangible property regulations, commonly referred to as the “repair” regulations.
    Published on May 01, 2012

    Guidance Issued on Interest Exceeding Acquisition and Home Equity Indebtedness Limitations

    Article The IRS recently released guidance for allocating excess mortgage interest expense.
    Published on May 01, 2012

    Foreign Limitations on Tax Loss Carryovers May Affect U.S. Foreign Tax Credits

    Article Many foreign countries have recently made statutory changes to their tax loss carryover periods and limitations that may affect the U.S. accounting for income taxes of any U.S. company with foreign subsidiaries operating in jurisdictions where the limitations have been enacted.
    Published on May 01, 2012

    Final Partnership Debt-for-Equity Regulations

    Article The IRS issued final regulations that provide guidance on the recognition of discharge of indebtedness income in partnership debt-for-equity transfers.
    Published on May 01, 2012

    Accuracy-Related Penalty Tested in Five Recent Cases

    Article In five recent cases, the Tax Court tested the defenses of various taxpayers to the imposition by the IRS of accuracy-related penalties for substantial understatements of income tax.
    Published on May 01, 2012

    Are Taxpayers Bound by Purchase Price Allocations

    Article A recent Tax Court opinion highlights the importance of preacquisition planning with respect to agreed-upon purchase price allocations in asset acquisition agreements under Sec. 1060.
    Published on May 01, 2012

    Removal of Sec. 163(j) Limitation Does Not Qualify as Accounting Method Change

    Article The IRS concluded that removing the Sec. 163(j) limitation on the deduction of interest paid on a loan from a related party does not qualify as an accounting method change under Sec. 446.
    Published on May 01, 2012

    Post-Implementation Review of FIN 48

    Article The Financial Accounting Foundation issued its Post-Implementation Review (PIR) Report on FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes.
    Published on May 01, 2012

    Tax Method Accounting Change Required for Change in Book Recognition on Multiple-Deliverable Contracts

    Article Taxpayers using the one-year deferral method to recognize advance payments on multiple-deliverable contracts for federal income tax purposes should note that a change in the underlying revenue recognition method used for book purposes could trigger a tax accounting method change in the year of the change.
    Published on May 01, 2012

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