Table of Contents - November 2007
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.
Bullets indicate items in the Tax Clinic department.
CHARITABLE CONTRIBUTIONS
• Gifting of a Remainder Interest in a Home
CREDITS AGAINST TAX
DEPRECIATION
• Placed-in-Service Decision Requires Careful Planning
EMPLOYEE BENEFITS & PENSIONS
IRS Clarifies NQDC Rules for Teachers
Current Developments in Employee Benefits and Pensions (Part I)
by Deborah Walker and Michael A. Haberman
Suggestions for Complying with Sec. 409A Deferred Compensation Plan Rules
EMPLOYMENT TAXES
Amended Regulations on the Student Exception from FICA Are Invalid
ESTATES, TRUSTS & GIFTS
• Prop. Regs. Address Deductibility of Trust and Estate Costs
EXPENSES
• Hurricane GO Zones: An Update on Relevant Tax Provisions
• New Prop. Regs. Clarify Tax Deductible Entertainment Use of Private Aircraft
Meeting the Home Office “Principal Place of Business” Requirement
FOREIGN INCOME & TAXPAYERS
• How to Avoid Triple Taxation Under the Branch Profits Tax and FIRPTA
• Notice 2007-13: Loosening the Rules Surrounding Substantial Assistance
• U.S. Individual’s Investment in Overseas Rental Property
The Impact of Sec. 897 on an NRA or Foreign Corporation’s Sale of Domestic Stock
GROSS INCOME
• Exercise of Options Using Borrowed Funds
• Tax Treatment of Compensation Received as a Nonprofessional Representative
Third Circuit Holds That Advance Payments of Trade Discounts Are Income on Receipt
INDIVIDUALS
Prop. Regs. on Dependency Exemption for Noncustodial Parent
INTEREST INCOME & EXPENSE
• Interest Deduction on Debt-Financed Distributions
PERSONAL FINANCIAL PLANNING
Tax Planning for the Use of TIPS at Retirement
by Richard B.Toolson
PRACTICE & PROCEDURES
AICPA Tax Division Relies on Volunteers
PROCEDURE & ADMINISTRATION
• Collection Due Process Hearing Regs. Upheld
REGULATIONS
Final Regs. on Dependent Care Expenses
S CORPORATIONS
• QSubs Recognized as Separate Entities for Employment and Excise Taxes
Current Developments in S Corporations (Part II)
by Stewart S. Karlinsky and Hughlene Burton
STATE & LOCAL TAXES
• Who Is Subject to the New Texas Margin Tax?
TAX EDUCATION
VITA, the MTC and the Modern Accounting Curriculum (Part II)


