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Articles from The Tax Adviser (June 1, 1995)

1-35 out of 35 article(s)
Title Author Type Words
Attribution rules applicable to commercial activities or controlled commercial entities of a foreign government for sec. 163(j) purposes. Sams, Jim 1746
Availability of 10-year carryback should be considered in light of IRS's ruling position. Conjura, Carol 1276
Avoiding penalties for failure to pay AMT: computation's complexity may abate penalties for individuals. Rook, Lance W. 3921
Business/nonbusiness income distinction subject to challenge. Evans, Marianne 1204
Closed year NOL may be increased if carryover year is open. Friedman, Steven M. Brief Article 294
Consolidated return election may mitigate stock basis decrease from phantom item. Rainey, Steven K. 2052
Continuing levy notice held applicable to commissions due independent contractor. Friedman, Steven M. 590
Correcting property contributions to qualified plans. Patterson, Martha Priddy 517
Determining the effects of a sale of deceased partner's interest by the successor in interest. Ellentuck, Albert B. 612
Employer payments for club dues, meals, entertainment and spousal travel. Yurkovic, Denis L. 459
FICA and FUTA taxes for deferred compensation. Patterson, Martha Priddy 719
Field directive says part-timers cannot be excluded. Yurkovic, Denis L. Brief Article 424
Filing of Form 3115 may be necessary by June 19, 1995 to obtain automatic approval (including audit relief) for changes to comply with final interest capitalization regulations. Conjura, Carol 1562
Gasoline wholesalers should consider opportunities presented by special gasoline tax refund procedure. Springer, Mark 1232
Gift tax return SOL - exception to the general rule. Watson, Mark T. 445
Incorporations and reorganizations involving qualified small business stock. Bailine, Richard W. 1062
Increasing-annuity payments make GRAT more attractive. Taylor, Rick J. 637
Minimizing AGI-based deduction limits by shifting family income: big savings possible despite the kiddie tax. Gervais, Paul L., Jr. 1989
Minimizing the generation-skipping transfer tax with thoughtful use of the $1 million GST exemption. Watson, Mark T. 1196
Pitfalls under new sec. 959 ordering rules. Fisher, Art 672
Property transferred in connection with performance of services. Cumberland, Brian 1022
Proposals for comprehensive tax reform. Bentley, Darcy 1115
Restoration of plan investment losses is not a contribution. Cumberland, Brian 718
Resurrecting transactions to qualify under secs. 338 and 338(h)(10). Bloom, Gilbert D. 1061
Sec. 197 antichurning rules - application of election to recognize gain on a sale of goodwill between related partnerships. Blumenreich, Richard G. 1330
Sec. 338(h)(10) - caveat target! Liquerman, Robert 932
Short-term capital gain distributions from a RIC - accounting income or corpus? Watson, Mark T. 555
TAM 9452002: redefining "control." (Technical Advice Memorandum) Bloom, Gilbert D. 848
Technological obsolescence may result in reduced personal property tax assessments. Smith, Scott D. 976
Termination for gross misconduct and COBRA rights. Patterson, Martha Priddy Brief Article 354
Termination of retiree health benefits. Cumberland, Brian 682
The audit lottery, or preparing for the TCMP audit - again! Goldberg, Walter S. 1289
Transfers from money purchase plan to profit-sharing plan. Yurkovic, Denis L. 1137
U.S. taxation of nonimmigrant students, teachers and trainees. Kenny, William J. 4676
When does the cash method clearly reflect income? Kalis, Jay 1311

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