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Table of Contents
March
2006

Note: In accordance with IRS Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers before the Internal Revenue Service, the information on this website is not intended or written to be used as, and cannot be used as or considered to be a “covered opinion” or other written tax advice, and should not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute or other purposes.

Asterisks indicate items in the Tax Clinic department.
 

Consolidated Returns

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Sec. 199 Prop. Regs. Clarify Treatment of Intercompany Transactions

 

Credits Against Tax

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Developing a Consistent Approach to the Sec. 41 Research Credit

  *

Overview of 2005 Developments on the Research Credit

     
Employee Benefits & Pension
   

Employer Contributions to HSAs

    Nonqualified Deferred Compensation Prop. Regs.
    Valuing Outstanding Stock Rights under Sec. 409A
    Roth 401(k)s
    PSC Retirement Agreements May Be Subject to Sec. 409A Prop. Regs.
  * Tax Consequences of Home Purchase Programs for Relocating Employees
     
Estates, Trusts & Gifts
    Stock-Purchase Agreement and Insurance Proceeds Disregarded in Valuation of Decedent’s Stock
     

Expenses

  *

IRS Rules on the “Commission-Based” Exceptions to Sec. 162(m)

   

Environmental Remediation Denied Sec. 1341 Relief Again

     

Gains & Losses

Residence Sale Exclusion Year-of-Death Rule

  * Hedge Identification and Timing Rules—Traps for the Unwary
  *

A Primer on Individual NOLs

     

Individuals

   

Treatment of Community Income for Spouses Living Apart (Part I) by Allan Karnes, Scott Salmon and Darla Karnes

   

Structuring Intrafamily Advances to Permit Bad Debt Deductions

     
Practice Management
   

Brainstorming to Identify and Manage Tax Risks by Mark S. Beasley, J. Gregory Jenkins and Roby B. Sawyers

    Document Retention
     
Procedures & Administration
   

Depositing and Reporting Income Tax Withholding

     
S Corporations
    Checklists for Determining whether a Trust Is a Valid S Shareholder
     
Special Industries
  *

Third Circuit Addresses Burden of Proof in Valuing Intangibles 

     
State & Local Taxes
    Current Corporate Income Tax Developments (Part I) by Karen J. Boucher and Shona Ponda
 
Reader Survey

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2006 AICPA