February 2009 - The Tax Adviser

Only one dependency exemption is allowed for a qualifying child and, since a single exemption cannot be shared, only one parent may claim it. As a result, there is often confusion and/or conflict between the parents.

This article gives an overview of the issues faced by practitioners when preparing Form 5471 and can serve as a roadmap to the potential problems and traps for the unwary.

In July 2008, the IRS issued a new Internal Revenue Manual (IRM) section that provides for an increased level of focus by IRS examiners to examine and enforce the statutory requirements for withholding and the related compliance reporting of FDAP-type payments to foreign persons.

This article reviews and analyzes recent rulings and decisions involving partnerships.