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October 2012 - The Tax Adviser

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S CORPORATIONS

Current Developments in S Corporations

During the period of this S corporation tax update, some major changes that directly affect S corporations took place. This article also presents tax planning ideas for S corporations and their shareholders.

Tax Clinic

DEPRECIATION

Depreciation and Changes in Use of Real Property

ESTATES, TRUSTS & GIFTS

Formula Marital Deduction Clause Not a Guaranteed Estate Tax Shelter

FOREIGN INCOME & TAXPAYERS

QEF Elections Under PFIC Rules

Potential U.S. Tax Consequences of Using Foreign Sales or Manufacturing Branches

IRS Issues Blueprint for IC-DISC Audits

GAINS & LOSSES

Timing a Loss Deduction

Ponzi Schemes, Clawbacks, and the Claim of Right Doctrine

S CORPORATIONS

Planning for Redemptions of S Corporation Stock Using Contingent Payments

Inadvertent S Corp. Terminations

STATE & LOCAL TAXES

Alternative Apportionment: Tough for the Taxpayer, (Too) Easy for the States

corporations & shareholders

Payments to Related Entities Are Dividends, Fail Independent-Investor Test

How Changes in Corporate Tax Rate Can Affect Choice of C vs. S Corp.

partners & partnerships

The Partnership “Technical Termination” Trap

Column

CASE STUDY

LLC Distributions of Contributed Property

DC CURRENTS

Watch for Further IRS Pronouncements on ITINs

Setting Up Firm Procedures to Fight Identity Theft

NEWS NOTES

Taxpayer Cannot Revive Equitable Innocent Spouse Claim

Prop. Regs. Clarify Who Is Subject to Limit on Meal and Entertainment Expenses

Model Intergovernmental FATCA Agreements Released; Draft Form Posted

IRS Permits Charitable Contributions to Single-Member LLCs

Final Regs. Issued on Entertainment Use of Business Aircraft

TAX PRACTICE & PROCEDURES

Statistical Sampling in Federal Tax Filings

Schedule UTP: IRS Findings

A Trust Fund Recovery Penalty Primer

TAX TRENDS

Taxpayers Not Insolvent for Purposes of Sec. 108 Exclusion

Taxpayer Liable for Willful Violation of FBAR Requirements

TAX PRACTICE MANAGEMENT

2025 tax software survey

AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.

Tax Clinic

IRS generally eliminates 5% safe harbor for determining beginning of construction for wind and solar projects

IRS proposes using NAICS to determine lines of business for certain fringe benefit exclusions

IRS rules that community trust and affiliated nonprofit corporation can file a single Form 990

Prop. regs. issued on new qualified tips deduction

IRS rules for first time that REIT’s income from markup on electricity from EV charging stations is rents from real property