January

    The Tax Adviser January 2013 

    Photo by Hemera/Thinkstock Articles

    Key Aspects of the New Tangible Property Regulations
    Susan E. Anderson

    Judicial Deference to Regulations: Home Concrete & Supply, LLC
    Donald T. Williamson and Blair Staley

    Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part II)
    Lawrence H. McNamara Jr.

    Accounting Method Changes Under the Tangible Property Regulations 
    Jane Rohrs and Natalie Tucker

     

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    Accounting Method Changes Under the Tangible Property Regulations

    Article This article details the method change rules under the current automatic consent procedural guidance and discusses the method changes that would be necessary to early adopt provisions of the temporary regulations.
    Published on January 11, 2013

    Judicial Deference to Regulations Home Concrete & Supply, LLC

    Article This article reviews the Supreme Court opinions and IRS regulations that gave rise to Home Concrete and analyzes how a deeply divided Supreme Court resolved the issue.
    Published on December 31, 2012

    When Is a Foreign Tax Creditable Under Sec. 901

    Article The Supreme Court has granted certiorari in a Third Circuit case to resolve a circuit split and to answer the question of when a foreign tax is creditable under Sec. 901.
    Published on December 31, 2012

    Corporation Sole Cannot Shelter Pastor From Tax Trouble

    Article A pastor’s use of a “corporation sole” structure to avoid “government interference” and a vow of poverty were not enough to shelter his income from federal tax, the Tax Court held in a recent decision.
    Published on December 31, 2012

    Updated Guidelines for Ex Parte Communications

    Article The IRS updated the rules on ex parte communications between IRS Office of Appeals (Appeals) employees and employees of other IRS functions.
    Published on December 31, 2012

    Significant Changes to Offer in Compromise Program

    Article The IRS published new guidelines for its offer in compromise program as part of its expansion of the “Fresh Start” program.
    Published on December 31, 2012

    The Number of No-Change Audits Is a Concern

    Article Two TIGTA audits are report that although the SB/SE audits recommended substantial adjustments, roughly 33% of all the audits in fiscal years (FYs) 2009–2011 resulted in no change.
    Published on December 31, 2012

    Disaster Relief Extensions Apply Only to Original Post-Casualty Dates

    Article When natural disasters strike, they often affect thousands or millions of taxpayers, and their effects can last for a long time. To provide some relief in these situations, the IRS often postpones various filing, deposit, and, sometimes, payment deadlines for affected taxpayers.
    Published on December 31, 2012

    Inadvertent Waiver of the Tax Practitioner Privilege Salem Financial, Inc.

    Article A decision by the Court of Federal Claims last year has important implications for tax practitioners who represent taxpayers before the IRS.
    Published on December 31, 2012

    FATCA Prop. Regs. Amended to Extend Various Deadlines

    Article The IRS is delaying various FATCA-related deadlines because it has received feedback that complying with the original deadlines and other requirements is proving to be impractical for some taxpayers.
    Published on December 31, 2012

    Key Aspects of the New Tangible Property Regulations

    Article Temporary regulations on expenditures to acquire, improve, and maintain tangible property significantly modify previous guidance and earlier proposed regulations.
    Published on December 31, 2012

    South Carolina Taxpayer Information Stolen

    Article South Carolina is providing affected taxpayers a year of credit monitoring after a hacker stole information including 3.8 million Social Security numbers and 387,000 credit and debit card numbers from its computer systems.
    Published on December 31, 2012

    IRS Announces Abatements of Frivolous Filing Penalty

    Article Taxpayers who have filed all required tax returns and paid all outstanding tax liabilities, including penalties (except for the Sec. 6702 penalty) and related interest, may qualify for a one-time reduction to $500 of any unpaid penalties that the IRS has assessed (Rev. Proc. 2012-43).
    Published on December 31, 2012

    IRS Provides Relief for Hurricane Sandy Victims

    Article In response to the extraordinary damage caused by Hurricane Sandy and the extreme need for relief, the IRS announced various tax relief measures for individuals and businesses affected by Hurricane Sandy in Connecticut, New Jersey, New York, and Rhode Island.
    Published on December 31, 2012

    Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part II)

    Article This two-part article explains the computations, payment, and reporting requirements for U.S. trust and estate distributions to foreign beneficiaries.
    Published on December 31, 2012

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