Table of Contents - September 2009
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.
Corporations & Shareholders
• Personal Intangibles: The Antichurning Rules
• Treatment of Grants as Nonshareholder Contributions to Capital
Depreciation
Guidance on Electing Not to Take 50% Bonus Depreciation
Estates, Trusts & Gifts
• Trusts Owning Partnership Interests
Significant Recent Developments in Estate Planning
Expenses & Deductions
• Merger Termination Fee Deductible
• Sec. 162(m)(5) Implications for TARP Recipients
Foreign Income & Taxpayers
• Preparing Canadian Structures for 2010
Gains & Losses
• Intangibles Can Be Like-Kind Property
Interests in LLCs and LLPs Not Presumed to Be Passive Activities
Gross Income
• Sec. 83 in the Context of Contract Manufacturing
Individuals
Chief Counsel Outlines Litigation Tactics for Innocent Spouse Cases
Partners & Partnerships
• Partnership Structural Changes: Deductibility of Expenses
Practice Management
Client Data Security for the Tax Practitioner
Procedure & Administration
ETAAC Makes Recommendations to Congress, Including Mandatory E-Filing
S Corporations
• Creative Ways of Achieving Grantor Trust Status
Deferring Shareholder Gain by Distributing Installment Notes
Special Industries
• Debt Restructurings in Today’s Private Equity Environment
State & Local Taxes
Drop Shipments and Flash Title: Establishing Sales Tax Nexus in Complex Commercial Transactions
Tax Accounting
• AMT Consequences of an Ownership Change
• Method Changes Within the Nonaccrual Experience Method
Maneuvering Through the Proposed Rules for Post-Transaction Accounting Methods
