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Articles
1-100 out of 100 article(s)
| Title |
Author |
Type |
Date |
Words |
| Final regs. on treatment of controlled services transactions under Sec. 482. |
Nevius, Alistair M. |
|
Oct 1, 2009 |
436 |
| Allocating liabilities among related partners: determining the impact of IPO II. |
Harris, Deanna Walton |
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Jun 1, 2009 |
2377 |
| Using statistical sampling to support the Sec. 199 deduction. |
Zaleski, Andy |
|
May 1, 2009 |
1491 |
| Navigating Secs. 743 and 734 in the current economy. |
Smith, Edward J., Jr.; Brandmeir, Zachary |
|
May 1, 2009 |
1868 |
| Target or waterfall: partnership allocations. |
Seaton, Jennifer; Henson, Jeremy |
|
Apr 1, 2009 |
2866 |
| Taxing the financial income of multinational enterprises by employing a hybrid formulary and arm's length allocation method. |
Benshalom, Ilan |
|
Jan 1, 2009 |
20639 |
| Limitations on taxpayers' ability to disavow tax consequences of contract terms. |
Keenan, John; Lagun, Julia |
|
Jan 1, 2009 |
1397 |
| Allocating passthrough items to S corporation shareholders. |
Ellentuck, Albert B. |
|
Dec 1, 2008 |
1205 |
| Installment sales: allocation of installment payments. |
Klunk, Jon R. |
|
Sep 1, 2008 |
1217 |
| IRS issues new rules on allocation of partnership items. |
Beavers, James |
|
Aug 1, 2008 |
855 |
| The quest to tax financial income in a global economy: emerging to an allocation phase. |
Benshalom, Ilan |
|
Jun 22, 2008 |
21792 |
| Rethinking tax nexus and apportionment: voice, exit, and the dormant commerce clause. |
Zelinsky, Edward A. |
|
Jun 22, 2008 |
30372 |
| VFJ Ventures, Inc. v. Surtees permissibility of Alabama's add-back statute: on April 29, 2008, Tax Executives Institute filed a brief amicus curae in with the Supreme Court of Alabama in VFJ Ventures, Inc. v. Surtees, relating to the permissibility of Alabama's add-back statute. |
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May 1, 2008 |
4075 |
| Maximizing the benefits of sec. 199 in an asset sale. |
Reinstein, Todd; Rolfes, Danielle E. |
|
May 1, 2008 |
2541 |
| TEI's follow-up comments on section 482 services regulations: on November 27, 2007, TEI submitted the following comments on temporary and proposed regulations relating to the treatment of services under section 482 (T.D. 9278) and revenue procedure 2007-13. |
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Jan 1, 2008 |
2179 |
| The houses that eminent domain and housing tax credits built: imagining a better New Orleans. |
Brown, Carol Necole; Williams, Serena M. |
|
Mar 1, 2007 |
13891 |
| Tax hikes aim to close budget gap. |
|
Brief article |
Feb 1, 2007 |
152 |
| Controlled services transactions. |
Laffie, Lesli S. |
|
Oct 1, 2006 |
837 |
| Withholding Requirements for Income Allocated to Foreign Partners. . |
Godfrey, Howard |
|
Oct 1, 2006 |
4817 |
| Withholding requirements for income allocated to foreign partners. |
Godfrey, Howard |
|
Sep 1, 2006 |
4682 |
| Allocation and apportionment of expenses for Sec. 199 purposes: for many taxpayers, calculation of the Sec. 199 deduction will require an enormous amount of work. This article focuses on one aspect of the deduction, the allocation and apportionment of expenses under the Sec. 861 regulations and the proposed Sec. 199 regulations. |
Kraay, Vickie |
|
Jun 1, 2006 |
5390 |
| Final Section 199 regulations clarify application of domestic production incentive. |
Vance, Scott |
|
May 1, 2006 |
3782 |
| Towards equity and efficiency in partnership allocations. |
Jones, Darryll K. |
|
Mar 22, 2006 |
23537 |
| Current developments. |
Burton, Hughlene A. |
|
Feb 1, 2006 |
4508 |
| Stock options and cost-sharing agreements. |
Laffie, Lesli S. |
|
Nov 1, 2005 |
412 |
| The "kiddie tax" on qualified dividends and net capital gains. |
Hulse, David S. |
|
Nov 1, 2005 |
1376 |
| TEI comments on proposed cost sharing regulations: November 28, 2005. |
|
|
Nov 1, 2005 |
10109 |
| Treatment of ownership changes for EIPs under Notice 2005-32. |
Velotta, Robert A. |
|
Aug 1, 2005 |
1686 |
| Partnership liabilities. |
Laffie, Lesli S. |
|
Aug 1, 2005 |
553 |
| Transfer pricing in Germany. |
Fabry, Peter |
|
Aug 1, 2005 |
1167 |
| Apportionment apoplexy: throwback, throwout, or just throw up your hands. |
Wilson, Margaret C. |
|
Jul 1, 2005 |
11398 |
| A winning tax shelter case. |
Jung, Do-Jin |
|
Jun 1, 2005 |
634 |
| Service scrutinizes inventory. |
Leib, Irwin A. |
|
Jun 1, 2005 |
2990 |
| New rules on FTC allocations. |
Shum, Michael G. |
|
Jun 1, 2005 |
2427 |
| Current corporate income tax developments. |
Ponda, Shona |
|
Apr 1, 2005 |
4776 |
| At-risk final regs. on "disqualifying interests". |
Howard, B. Carol |
|
Nov 1, 2004 |
1275 |
| IRS relief for missed allocations of GST exemption. |
Sherr, Eileen |
|
Oct 1, 2004 |
267 |
| Sec. 351 transfers involving boot and encumbered assets. |
Keller, Brian E. |
|
Sep 1, 2004 |
1954 |
| Reverse sec. 704(c) allocations for securities partnerships. |
Miller, Sarah Allen |
|
Sep 1, 2004 |
1440 |
| Divorce agreement language: proper wording in divorce documents is crucial. |
Maples, Larry |
|
Sep 1, 2004 |
3428 |
| Debt allocation and LLCs. |
Schnee, Edward J. |
|
Sep 1, 2004 |
584 |
| Are unallocated support payments alimony? |
Hawley, Richard C. |
|
Aug 1, 2004 |
626 |
| IRS revises allocation rules for charitable contributions. |
|
|
Jul 1, 2004 |
388 |
| Rev. Rul. permits allocation of expenses to former employees. |
Masnik, Robert H. |
|
Jun 1, 2004 |
722 |
| NY administrative ruling addresses numerous apportionment issues. |
Amitay, Sharlene |
|
Jun 1, 2004 |
860 |
| Taxation of damages from securities lawsuits. |
Hanson, Randall K. |
|
Apr 1, 2004 |
3691 |
| Nuts and bolts of LLC and partnership taxation. |
|
Brief Article |
Sep 1, 2003 |
58 |
| Allocating settlement proceeds in employment cases. |
Monroe, Tracy J. |
|
Aug 1, 2003 |
1573 |
| Tax allocations for securities partnerships. |
Bellamy, Chris |
|
Aug 1, 2003 |
1802 |
| In the Supreme Court of United States: Unisys Corporation, Petitioner, v. Pennsylvania Board of Finance and Revenue, Respondent. On Petition for a Writ of Certiorari to the Supreme Court of Pennsylvania: Brief of Tax Executives Institute, Inc. as amicus curiae in support of petitioner. |
|
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Jul 1, 2003 |
5710 |
| Taxing the sale of a business. |
Schnee, Edward J. |
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Jul 1, 2003 |
630 |
| Partnership items. |
Schnee, Edward J. |
|
Jun 1, 2003 |
661 |
| Final regs. on allocating income between U.S. and possessions. |
Thomas, Jim |
|
Mar 1, 1999 |
1074 |
| The TRA '97's new basis allocation rules for property distributions. |
Streer, Paul J. |
|
Jul 1, 1998 |
5724 |
| States quickly modify apportionment provisions in reaction to changes in financial institutions industry. |
Boucher, Karen J. |
|
Nov 1, 1997 |
1724 |
| Depreciation planning for newly acquired commercial real estate. |
Keeley, Karen M. |
|
Oct 1, 1997 |
1614 |
| Beware not allocating the GSTT exemption on a gift tax return - a trap for the unwary. |
Sherr, Eileen Reichenberg |
|
Aug 1, 1997 |
2143 |
| Amendments to the sec. 1060 and 338(b) regulations conforming allocation of purchase price to the 1993 intangibles legislation. |
Eisenberg, Andrew M. |
|
Jun 1, 1997 |
1405 |
| Is sec. 704(c) or sale treatment better for a contributing partner? |
Holbrook, Terri L. |
|
May 1, 1997 |
1271 |
| Planning ideas under the new consolidated sec. 382 regulations. |
Friedel, David |
|
Apr 1, 1997 |
779 |
| Allocation and apportionment of charitable contributions under section 861. |
|
|
Mar 1, 1997 |
4263 |
| Current corporate income tax developments. |
Boucher, Karen J. |
|
Mar 1, 1997 |
6928 |
| GST tax exemption - late allocation issues. |
Kelley, Duane G. |
|
Dec 1, 1996 |
1312 |
| Interest expense allocation related to debt-financed distributions from a passthrough entity. |
Schulz, Charles P. |
|
Dec 1, 1996 |
471 |
| Allocation of nonrecourse debt under the three-tier sec. 752 allocation process. |
Ellentuck, Albert B. |
|
Oct 1, 1996 |
1516 |
| IRS issues proposed regulations on allocation and apportionment of research and experimental expenditures. |
Goodman, Mark E. |
|
Sep 1, 1996 |
1133 |
| The single sales factor - a new trend? |
Esstman, Donald L. |
|
Sep 1, 1996 |
784 |
| Massachusetts single-sales factor apportionment. |
Joseph, Douglas A. |
|
Sep 1, 1996 |
832 |
| The increased importance of inventory valuations in purchase price allocations. |
Whalen, Rich |
|
Jul 1, 1996 |
657 |
| Proposed section 863(b) regulations: sourcing of income from export sales. |
|
|
Jul 1, 1996 |
2789 |
| Allocations using a reasonable method other than those specifically stated in regulations. |
Ellentuck, Albert B. |
|
Jun 1, 1996 |
860 |
| Final cost-sharing regulations. |
Dicker, Adrian J.W. |
|
May 1, 1996 |
702 |
| Final regs. clarify basis and distribution issues, but leave unanswered questions. |
Duncan, William A. |
|
May 1, 1996 |
7212 |
| Coordination of elections by S shareholders to close the books for allocation purposes. |
Payne, Jay |
Brief Article |
Apr 1, 1996 |
486 |
| Partnership's allocation method satisfies sec. 704(b) and (c). |
Castle, Creighton |
|
Jan 1, 1996 |
497 |
| Allocating allowable sec. 1244 loss among shareholders when total capital exceeds $1 million. |
Ellentuck, Albert B. |
|
Jan 1, 1996 |
1081 |
| A sec. 179 deduction trap. |
Botkin, Jeffri |
Brief Article |
Dec 1, 1995 |
372 |
| Proposed Section 861 regulations. |
|
|
Nov 1, 1995 |
2985 |
| Regulations on allocations relating to contributed property affect securities partnerships. |
Dance, Glenn E. |
|
Nov 1, 1995 |
504 |
| Planning for distribution of partnership interest at death. |
Torrance, Debbie R. |
|
Oct 1, 1995 |
707 |
| Planning around the CFC netting rule. |
Bond, Dale |
|
Jul 1, 1995 |
930 |
| Age-weighted profit-sharing plans may benefit small companies. |
Warren, Joseph F., Jr. |
Brief Article |
May 1, 1995 |
194 |
| Accounting for book-tax differences of property contributed to a partnership. |
Walsh, Joseph G. |
|
May 1, 1995 |
5159 |
| Accounting for book-tax differences of property contributed to a partnership. |
Walsh, Joseph G. |
|
Apr 1, 1995 |
6924 |
| Final sec. 704(c) regulations issued. |
Edquist, David |
|
Apr 1, 1995 |
574 |
| Responding to the new subsidiary investment and earnings and profits consolidated return regulations. |
Bean, Robert L. |
|
Mar 1, 1995 |
3706 |
| Allocations relating to property contributed to partnership. |
Dance, Glenn E. |
|
Nov 1, 1994 |
1400 |
| Accounting for the value of a partner's services. |
Ellentuck, Albert B. |
|
Oct 1, 1994 |
591 |
| Tax Court specifies conditions for accepting settlement allocations. |
Sager, Clayton R. |
|
Sep 1, 1994 |
1360 |
| Sec. 467 revisited: payments vs. allocations. |
Orbach, Kenneth N. |
|
Sep 1, 1994 |
1032 |
| AMT credits allocated in a consolidated group. |
Yelvington, Brenda |
|
Aug 1, 1994 |
1613 |
| Several options available for property contributed to a partnership. |
Edquist, David |
|
Jul 1, 1994 |
6572 |
| Rent allocated to foreign corporation subject to gross income tax. |
Burge, Marianne |
Brief Article |
Jul 1, 1994 |
441 |
| Determining the amount of the disallowance of lobbying expenses. |
Connor, Jim |
|
Apr 1, 1994 |
735 |
| New regulations clarify partnership allocations related to contributed property. |
Lux, Michael |
Brief Article |
Mar 1, 1994 |
330 |
| Limitation increase rule revoked by proposed regulations. |
Coughlin, Theresa A. |
|
Jul 1, 1993 |
764 |
| Figuring unrelated business income tax the IRS way. |
Duren, David M. |
Cover Story |
Jun 1, 1993 |
7667 |
| Allocations of nonrecourse deductions and the minimum gain chargeback. |
Martin, M. Jill |
|
Dec 1, 1992 |
2573 |
| Reasonable joint cost allocations in nonprofits. |
Tishlias, Dennis P. |
|
Nov 1, 1992 |
2093 |
| Allocation of partnership liabilities. |
Dennis, William A., Jr. |
|
Aug 1, 1992 |
4680 |
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