Under the economic outlay doctrine, to obtain basis in an S corporation with respect to debt, a shareholder must make an actual economic outlay, the outlay must somehow leave the shareholder poorer in a material sense, and the debt created must run directly between the shareholder and the S corporation.
May 2009 - The Tax Adviser
PRACTICE & PROCEDURES
Preview and Analysis of Proposed Statements on Standards for Tax Services
The AICPA’s Tax Executive Committee released an exposure draft of proposed Statements for Tax Services (SSTS Nos. 1-7) on November 26, 2008.
PRACTICE & PROCEDURES
New Tax Preparer Rules for Disclosure and Use of Return Information
The IRS released final regulations under Sec. 7216, providing guidance for tax return preparers about the disclosure or use of tax return information.